Apart from the families of the victims, there were others who suffered as a result of the accident and its aftermath. One of those was Captain Leslie Simpson, who at the same briefing as Captain Collins on 9 November 1979 and who commanded the Antarctic flight of 14 November 1979. His evidence was relied on by ALPA to establish that the McMurdo waypoint conveyed during the briefing was not at McMurdo Station but was, instead, some miles away, out to the west. The significance was that on the night before his flight, Captain Collins plotted the track, using a print-out of a flight plan. Given what occurred the next day, that flight plan must have had the McMurdo waypoint away from McMurdo Station, out to the west. If the waypoint conveyed during the briefing was at McMurdo Station, Captain Collins’s plotting exercise would have revealed a conflict, which he was obliged to resolve.

The briefing of 9 November 1979 was in two parts. The first part consisted of an audio-visual presentation conducted by Captain John Wilson. The second part was a simulator exercise conducted by Captain Ross Johnson. Both were adamant that the McMurdo waypoint conveyed during the briefing was nowhere other than McMurdo Station. Both witnesses’ evidence was confirmed by other independent evidence. As regards Captain Wilson, his evidence was confirmed by the typewritten script used for the audio-visual presentation. As regards Captain Johnson, his evidence was confirmed by what occurred during the simulator exercise, when the simulator was repositioned to the McMurdo waypoint. It ended up at McMurdo Station, not miles out to the west.

Problems with Captain Simpson’s Evidence

Captain Simpson’s evidence was that the position of the waypoint conveyed during the briefing was not at McMurdo Station. The first problem with that evidence was that Captain Simpson sat through the audio-visual presentation and completed the simulator exercise, during which he was presented with information that the waypoint was at McMurdo Station, not somewhere else - but he did not ask any question about the position of the waypoint.

As to the source of his belief about the position of the waypoint, Captain Simpson referred to a print-out of a flight plan that he sighted during the briefing. It has always been assumed that the print-out was for a flight of two weeks earlier where the latitude of the McMurdo waypoint was 164 degrees east, being two full degrees west of McMurdo Station at 166 degrees. Captain Simpson’s evidence was that he related the waypoint to a map available at the briefing and estimated that the distance between the waypoint and McMurdo Station was about 10 nautical miles. The problem with that evidence was that the map had a scale which made it obvious that the distance was well over 20 nautical miles.

Captain Wilson’s Print-Outs of Flight Plans

Captain Wilson brought four print-outs of flight plans to the briefing. They were all from a flight he had been on, two weeks before. One was for the route to the McMurdo area and one was for the alternate route to the South Magnetic Pole (which, for obvious reasons, did not have had any waypoint for the McMurdo area). The other two print-outs were for the same two routes but were the “as flown” versions, being the same print-out with various handwritten notations recording what occurred during the flight.

On the two print-outs of flights to the McMurdo area the longitude of the McMurdo waypoint was 164 degrees.

In the unmarked version of the flight plan to the McMurdo area, the waypoint was underlined.(MacFarlane p79)  In the “as flown” version, the waypoint was highlighted. (Exhibit 206C)

Waypoint Underlined / Highlighted

First Officer Gabriel, seated next to Captain Simpson at the briefing, said: “During the talk through of these notes Captain Wilson handed out some flight plans from a previous Antarctic flight. He told us that they were there for us to look at but we were not to take them away with us. I looked at a flight plan depicting a route to McMurdo and I remember that the McMurdo waypoint was underlined or highlighted in some way.” (MacFarlane p232)

The statement about seeing the waypoint underlined or highlighted was in the written statement prepared for First Officer Gabriel by ALPA. The significance of his reference to underlining/highlighting was that no similar statement was made by Captain Simpson, who was also called as a witness by ALPA.

It was clearly in ALPA’s interests to have Captain Simpson looking at an underlined / highlighted waypoint with a longitude of 164 degrees. There is little doubt that ALPA would have asked Captain Simpson if he observed any underlining or highlighting, to which his answer must have been ‘no’. Given the lack of any reference by Captain Simpson to underlining/highlighting, it possible that he was not looking at one of the two McMurdo area print-outs brought to the briefing by Captain Wilson, because the waypoint on one was underlined and on the other was highlighted.

Other Print-Outs

Captain Simpson was interviewed by Ron Chippendale in March 1980. The interview was taped and transcribed, and the transcript was sent to Captain Simpson for corrections to be made. The transcript included the following: “[Captain Wilson] had some old flight plans from previous years flights which he handed out for us to just look at, but didn’t have enough to give away.” (emphasis added) (MacFarlane p354)

The print-outs of flight plans brought to the briefing by Captain Wilson were for a flight of the previous fortnight so would not be covered by  the phrase “previous years flights”. This raises a question as to whether there were other print-outs available at the briefing. There was at least one such document, that being the print-out used to enter the waypoints at the beginning of the simulator exercise.

Simulator Exercise

According to Captain Johnson, the waypoints were entered by First Officer Cassin, using a flight plan from October 1977. (MacFarlane p220) At that time the waypoint was the NDB at McMurdo Station, with a longitude of 166 degrees. Although some of Captain Johnson’s evidence was disputed, no issue was taken with what he said about the entry of the waypoints.

One of the purposes of the simulator exercise was to practise a cloud-break procedure overhead the NDB at McMurdo Station. After practising the change to grid navigation at 60 degrees south the simulator was repositioned to the McMurdo waypoint. Had one of Captain Wilson’s print-outs been used to program the simulator, it would have ended up over 20 miles west of McMurdo Station. There was no evidence from anyone about the simulator ending up in a wrong location.

First Officer Cassin entered the waypoints, using a print-out of a flight plan dated October 1977. He was also on the accident flight, in the wreckage of which was found a print-out of a flight plan, dated October 1977 (MacFarlane p104)– so First Officer Cassin may well have retained the print-out he used to program the simulator. Whatever the event, there would have been numerous opportunities during the briefing for Captain Simpson to sight the print-out and observe the longitude of the McMurdo waypoint which, if it was the October 1977 print-out, would have been 166 degrees. Significantly, the McMurdo waypoint on the October 1977 print-out recovered from the wreckage had no underlining or highlighting, which is consistent the lack of any reference to the topic in Captain Simpson’s evidence.

The October 1977 print-out is consistent with the other evidence. It explains why Captain Simpson did not ask any question about the position of the McMurdo waypoint. He could see that it was at McMurdo Station, which is where he would have expected it to be, and where the audio-visual presentation was telling him it was, and where the simulator exercise was telling him it was. (Given the lack of maps at the briefing, he did not then know that a track to McMurdo Station would cross the summit of Erebus.)

The October 1977 print-out is also consistent with Captain Simpson’s  being surprised when he discovered that the waypoint was actually more than 20 miles west of McMurdo Station.

Captain Simpson Noticed A Difference Between Positions

Right from day one Captain Simpson, in reference to the briefing, spoke of his noticing a difference between positions when he looked at the print-out of the flight plan. It has always been assumed that he was looking at one of Captain Wilson’s print-outs and that the difference was the difference between the position of McMurdo Station and the position of the McMurdo waypoint, more than 20 miles west. If that was the difference he was referring to, his evidence made no sense.

If, in reality, Captain Simpson was looking at the October 1977 flight plan when he noted a difference between positions, things fall into place. There was a difference between positions, but it was a much smaller one, nowhere near 20 miles. Captain Wilson wrote the co-ordinates of the TACAN on one of the hand-outs. The TACAN was not located at McMurdo Station. It was to the south-east, by Williams Field, being the ice runway. The longitude of the TACAN was 166 degrees 58 minutes. The longitude on the October 1977 print-out was 166 degrees 41 minutes, a difference of 17 minutes. Captain Simpson would have quickly concluded that McMurdo Station was a few miles west of the TACAN.

Captain Simpson’s Flight

If it is assumed that the difference noted by Captain Simpson was that between the TACAN and McMurdo Station, that is completely consistent with what occurred during Captain Simpson’s flight. He had good weather, so did not need to fly in nav mode. Nevertheless, he monitored his position in relation to the nav track. By the end of the sound he was well to the right of track. He then turned left and headed towards the McMurdo Station / Williams field area. He believed that the waypoint was at McMurdo Station so he would therefore be going left of track after passing McMurdo Station and continuing on to TACAN, given the few miles difference he had observed during the briefing. Instead, the difference was well over 20 miles, hence his surprise.

The AINS was vital for the return journey and Captain Simpson was concerned that it might be malfunctioning, so he performed an update over the TACAN and another over Coleman Island. Then, after he got home, he plotted the waypoint, but not using the October 1977 print-out, because he did not have it. He used the print-out for his own flight, where the longitude of the waypoint was 164 degrees and concluded that there was no malfunction. Given that the difference in position, which he now knew to be over 20 miles, had caused him to perform two unnecessary updates, he suggested to Captain Johnson that future crews be informed.

Captain Simpson’s Initial Statements

A sighting of the October 1977 print-out at the briefing and a resulting belief that the waypoint was at McMurdo Station are also consistent with Captain Simpson’s initial statements, when he used his own words. Things only started to go awry when his apparent words were actually those of ALPA.

The captain’s first interview with Ron Chippendale was on 14 December 1979, two weeks after the accident.  Captain Simpson was asked to make a note recording his recollection of the interview. The note contained the following:

“Did Captain Collins contact you after your flight, or did you discuss your flight with him?

No, but I did telephone Captain Johnson, who was involved with the Antarctic flights, with the suggestion that it would be a good idea to point out to future crews going on Antarctic flights, that the McMurdo position on the flight plan was to the west of the McMurdo TACAN co-ordinates, so they would carefully consider any normal across track errors before rushing into a manual update over the McMurdo Base area. Although I had been expecting to be going left of the R.NAV track when flying visually on heading to track over the airfield area, I had been somewhat surprised to see it as much as 28 miles left, when over the TACAN.” (MacFarlane p353)

The same matter was referred to in the March 1980 interview, but in more detail:

“Could you tell us where you expected to approach, from what direction, and over what area you expected to approach McMurdo and how you discovered the error in the Area Nav System?

Well on the flight plans that were handed out at the briefing, I had actually compared the co-ordinates of the McMurdo Nav position on the Ross area chart in relation to the TACAN and without measuring it as to how far it was west I did note that it appeared close to the edge of the ice shelf, somewhat to the true west of McMurdo Base. On the flight down from Cape Hallett, I was flying visually towards the Dry Valley area noting that the Area Nav cross-track was going as expected up to about 30 miles right of track, and from the Wright Valley we then headed visually towards McMurdo Base, which we could see, and descending to 6000 feet over the top of McMurdo. We closed the track and then proceeded to go left of the Area Nav Track, and as the distance increased beyond 25 miles left as we approached McMurdo, I made comment to my co-pilot that the area nav seemed to be going excessively left of track. He agreed, he thought the same. So we decided we would do a manual up-date as close as we could to overhead the TACAN position. When the TACAN was reading one mile and we appeared visually over the top, the co-pilot proceeded with the manual up-date, inserting the TACAN co-ordinates. At that stage I was more concerned with flying the aircraft visually than actually looking at the computer readout to see whether in fact there was an error between the frozen co-ordinates and the TACAN co-ordinates before the update. Later, on the climb back towards Cape Hallett when I was able to relax more and think about the up-date, I thought that the Area Nav may have been fairly right, and we did another manual up-date, just to make sure it was correct for the flight back to New Zealand, overhead Coleman Island. I had an extra flight plan printout which I had requested from Flight Despatch prior to departure and when I got home I sat down and compared the computer McMurdo position with the TACAN position on the chart, and decided, in actual fact, our Area Nav was probably quite accurate at the McMurdo position, so the next morning I rang Captain Ross Johnson, who had been mainly concerned with the briefings and the organisation of the Antarctic flights, telling him that in my opinion it would be a good idea to advise the subsequent crews going down to Antarctica of the difference between the Area Nav McMurdo position and the TACAN position, so they would considered carefully any cross-track errors that they might note, before they rushed into manually updating their Area Nav.” (MacFarlane p357)

Everything in the above two statements is consistent with Captain Simpson sighting the October 1977 print-out at the briefing, leading to a belief, during his flight, that the waypoint was at McMurdo Station. There is only one possible exception, that being the following sentence:

“Well on the flight plans that were handed out at the briefing, I had actually compared the co-ordinates of the McMurdo Nav position on the Ross area chart in relation to the TACAN and without measuring it as to how far it was west I did note that it appeared close to the edge of the ice shelf, somewhat to the true west of McMurdo Base.”

Captain Simpson used the phrase “McMurdo Base”. That is not necessarily the same as “McMurdo Station”, given that different things were located in different places. Note that in the first statement he used the phrase “McMurdo Base” to refer to the area where a manual update would take place. Given that the any manual update would be done using the TACAN, he was using the phrase to refer to the airfield area, not McMurdo Station. He may well have been using the phrase in the same way during the second interview. In that interview, Captain Simpson also used the phrase “McMurdo Base” with “which we could see”. Flying towards the McMurdo Station / Williams Field area, the first thing a pilot would see would be the distinctive cross in the ice made by the two intersecting runways. To demonstrate, look at the sixth page of the following document:

http://www.erebus.co.nz/Portals/4/Documents/articles/The%20Antarctic%20Experience%20-%20pdf%20of%20brochure.pdf

It's a large photograph looking down on Mount Erebus. The intersecting runways are in the distance.

It is more probable than not, therefore, that Captain Simpson used the phrase “McMurdo Base” to refer to the location of the airfield and the TACAN, and that when he referred to the “McMurdo Nav position” he was referring to the co-ordinates of the NDB at McMurdo Station, shown on the October 1977 print-out.

The Cause Of Captain Simpson’s Evidence

If the position of the McMurdo waypoint conveyed to Captain Simpson during the briefing was at McMurdo Station, why did he give different evidence?

It should be noted that Captain Simpson did not take any print-out from the briefing. When he returned from his flight and plotted the waypoint, he would have been puzzled as to why he had thought it was at McMurdo Station but he was not able to go back and check the print-out he sighted at the briefing because he did not have it.

If Captain Simpson did not know that the October 1977 print-out was available at the briefing then, as the days passed, he would have come to assume that he must have been looking at one of Captain Wilson’s print-outs. His mind would naturally seek to explain things by way of some rational explanation. He would also be far more open than usual  to suggestions as to how the contradictions might be resolved.

Another Potential Cause: ALPA

At page 661 of MacFarlane’s book there is a quote from a ‘New Zealand Wings’ article in June 1986:

“[Captain Simpson] told me that he had written his statement for presentation to the Court and submitted it to NZALPA’s lawyers. It eventually came back to the pilot for him to present to the Court in a version which bore no resemblance to the one he had written. He refused to present it in that form and re-wrote it in a manner which he considered might be acceptable to NZALPA’s lawyers, but still represented the facts as he knew them. After a while his statement came back, “doctored” yet again. Yet again he re-wrote it. This back and forth process went on until the version given at the hearing by this witness was not received by him until the morning of the day he was scheduled to present his evidence. He wasn’t happy with it but it was a lot closer to his original so, due to the time constraint, he went ahead and presented it.”

MacFarlane then launches into Captain Simpson, ending on page 670 with a reference to allegedly inconsistent statements. Any perceived inconsistency is explained by the scenario outlined above: At the briefing, Captain Simpson sighted the October 1977 print-out, not one of Captain Wilson’s 1979 print-outs.

It is sometimes said of a person that “with friends like that, who needs enemies?” MacFarlane is a perfect candidate, because in his strenuous efforts on behalf of ALPA, he discloses information that has the opposite effect.

By way of background, Air New Zealand conducted Antarctic flights for three years: 1977, 1978 and 1979. In 1977 the waypoint was at 166 degrees. In 1978 and 1979, it was at 164 degrees, until being changed back just before the accident flight.

ALPA’s case depended on Captain Simpson looking at a print-out with a waypoint at 164 degrees and therefore depended on him looking at a print-out from either 1978 or 1979. A print-out from 1977 was no good.

In his statement of March 1980, Captain Simpson used the phrase “previous years flights” in reference to the print-out/s he sighted. That phrase is slightly ambiguous but it could be interpreted as including both 1977 and 1978 and so including the October 1977 print-out. If, on the other hand, the phrase was something like “a flight of the previous year” there would be no ambiguity and the October 1977 print-out would be excluded.

At page 353 MacFarlane advises that a copy of Captain Simpson’s March 1980 statement was given to ALPA’s lawyers.

At the bottom of page 662 MacFarlane refers to an interview between Captain Simpson and ALPA’s lawyers, after which ALPA’s lawyers  prepared a draft statement and posted it to Captain Simpson.

At page 664 MacFarlane tells the reader that the draft statement contained the following: “During the briefing Captain J.P. Wilson produced a flight plan from a flight of the previous year for our perusal.” (emphasis added)

Captain Simpson’s own words were “previous years flights”, leaving open the possibility of his having sighted the October 1977 print-out. ALPA’s lawyers had those words but instead of using them there   was an apparently-minor change, which Captain Simpson probably did not notice. The effect of that change was to lock Captain Simpson into the desired position and exclude the possibility of his having sighted the October 1977 print-out, thereby advancing ALPA’s case.

It would be interesting to know whether anyone at any time ever raised with Captain Simpson the possibility that he might have actually sighted the October 1977 print-out. I suspect not.

"The "previous year" was 1978, all of the flight plans for which contained the "Dailey Island" McMurdo waypoint.  If they had a separate copy of the 1977 flight plan for entering the NDB co-ordinates, then that's another separate and unrelated matter.  If it was Cassin who entered the co-ordinates, it'd make sense that he might still have had that copy - which would further imply that the "previous year" copies handed out by Wilson - which had to be returned - were not the same thing as the 1977 plans used in the sim."

None of that has anything to do with it. The point is that ALPA changed the wording, from one that included 1977 to one that did not.

"You may read things differently, but to my mind nothing in the quotes from Simpson you have included above indicate in any way that he was expecting the waypoint to be over McMurdo Station."

The quotes themselves do not confirm that Captain Simpson believed that the waypoint was at McMurdo Station. They are, however, consistent with such a belief. The alternative belief is that the waypoint was 10 miles west of McMurdo Station, that being the one that eventually made its way into the evidence presented to the Royal Commission. The problem with that is that there were nearly two full degrees of longitude between the Dailey Islands waypoint and McMurdo Station. At the equator, that would be 120 nautical miles. Obviously, the lines converge as they approach the poles, but the inset to NZMS135, the only map available, had a scale which made it obvious that the distance was over 20 miles. Page 680 of McFarlane’s book sets out the cross-examination of Captain Simpson on that point. He was not able to provide any explanation. (He was not then aware of the possibility that the flight plan he sighted might have been the October 1977 print-out).

"This is especially relevant if you consider what happened to Gordon Vette - ANZ were forced to reinstate him, but added the stipulation that he must be supervised.”

Where did you get that piece of nonsense from? “reinstate him”? Vette wasn’t dismissed, or demoted. Some AirNZ staff were suspended after the report was released in 1981 but Vette wasn’t one of them.

"Wait a minute - you said in your previous post that it was NZALPA's *lawyers* who changed the wording, which is a rather different kettle of fish." 

Oops, you’ve got me. Let me change it to “ALPA’s lawyers changed the wording”. Does it make any difference? Of course not.

"I thank you for sharing the information on the sim exercise, and after a bit of thought I had to wonder - just what exactly was the practical purpose of practicing an NDB let-down procedure in the sim using the actual co-ordinates (from a 2-years obsolete flight plan) of an NDB which by then had been withdrawn from service for quite some time?"

Who cares? The point is that the waypoint conveyed by the simulator exercise was at McMurdo Station, not 20 miles west.

 “The alternative belief is that the waypoint was 10 miles west of McMurdo Station.” That's a false dichotomy, to be fair - there's nothing to say that he didn't believe the waypoint was at 164.48 as he had been briefed"

Whatever a “false dichotomy” might be, that’s wrong: If that was his belief there would have been nothing to be surprised about.

"I didn't say [Vette] was dismissed, demoted or suspended.  The reference is in Holmes Chapter 22 (I can't give you a page number/para as my copy is on my Kindle), and refers to his being returned to the "flying roster".  It may be that he left the flying roster voluntarily to do his research - I didn't say anything about the company penalising him directly.  The book states that he was subjected to checks on long hauls (doesn't specify how many were required) on his return to the roster and it was Gemmell who personally checked him, making the atmosphere on the flight deck very uncomfortable."

Another example of Holmes getting things wrong. Incidentally, Vette died last month. He and Gemmell joined TEAL after WW2 as aircraft technicians, so they knew eachother very well. In 1979 Vette was not an “executive pilot” – but he could have been if he had wanted to. In that regard, it should be noted that there was more work and that although the pay was slightly higher, that would be offset by the higher amount of surplus expense allowances received by those on the “flying roster” – which Vette did not return to, because he never left it.  All the pilots, including the executive pilots, had to undergo periodic route checks. The executive pilots were all very senior, so who do we get to check them? Obvious answer: Vette – and that’s what he did. Next question: Who do we get to check Vette? Obvious answer: The chief pilot, Gemmell.

“”Oops, you’ve got me. Let me change it to “ALPA’s lawyers changed the wording”. Does it make any difference? Of course not.”  With respect, I went into some detail as to why I believe it could well make a difference.  I assure you that I take the time to read your posts thoroughly before replying, and I'd hope you'd be willing to do me the same courtesy.”

Oh, very well then, if you insist. This is what you wrote regarding the significance of the involvement of ALPA’s lawyers:

“Of the few people I know who work within the legal system, on the occasions I've asked them to "talk shop", the discussion has usually included the point that when it comes to written submissions, regardless of the position of the client, it is standard practice for legal staff to redraft in such a way that statements which could be read as ambiguous *must* be reworded such that any ambiguity (which tends to crop up fairly often) is removed or resolved.  Whether the context is a criminal or civil case - or, indeed, a Royal Commission; the assumption has to be that opposing counsel will see any ambiguity as an opportunity to discredit their position - from a single witness to an entire case - as much as they can.”

Written submissions are the lawyer’s own words so there is, obviously, every reason to remove ambiguities. Witnesses' statements are different. They are not the lawyer’s own words. If the witness has provided a written statement containing an ambiguity, there are two choices: (1) Leave the words as they are; (2) Resolve the ambiguity. If, during the interview with Captain Simpson, ALPA’s lawyers asked him whether he was referring to 1977 or 1978, and if Captain Simpson told them that it was 1978, then change the wording, by all means. But if nothing was said, and if the changed wording was slipped in in an attempt to trap Captain Simpson into a position that suited ALPA, then that was completely improper. So which scenario is more likely? The latter, because there is no evidence of there being any 1978 flight plan at the briefing. The only flight plans known to have been at the briefing were from 1977 and 1979.

“My feeling (for what it's worth) is that this routine lawyers' practice, rather than an attempt on ALPA's part to steer Capt. Simpson, was the reason for the re-drafting of that particular part of the submission.  For one thing, and as I alluded to earlier, if Capt. Simpson felt that rewording in particular did not reflect his intent, even at that late stage all he had to do was to clarify that "previous year" could have referred to a '77 or '78 flight plan during his testimony and there would have been nothing that NZALPA or their counsel could do about it.”

Put yourself in Captain Simpson’s position. He knows nothing about the changing location of the waypoint, so the 1977/1978 matter is of no significance to him, and the two phrases look very similar. He certainly could have clarified things, if one of the 15 lawyers present at the hearing had asked him to, but none did. By the time of the hearing, Captain Simpson probably would have come round to the belief that the print-out he sighted at the briefing was that of Captain Wilson’s, dated 1979, so if asked, he would have said that he was mistaken in saying it was from the previous year.

“ “Whatever a “false dichotomy” might be, that’s wrong: If that was his belief there would have been nothing to be surprised about.”  It's an attempt to state that the matter concerned can only be one of two things when in reality there are actually more possibilities.  I explained my reasoning above, if you'd care to read it.”

 I read it. Being unable to understand it, I left it out of my response. Here it is:

“That's a false dichotomy, to be fair - there's nothing to say that he didn't believe the waypoint was at 164.48 as he had been briefed - again, the only statement he makes regarding concern about the waypoint location is how far away it was from the TACAN.  This doesn't necessarily have anything to do with his recollection of the briefing, just an understandable concern from a piloting perspective that the waypoint was quite so far from the nearest ground aid, which would generally be considered somewhat unusual. “

Still don't understand it: Are you referring to Captain Simpson or Captain Collins? Whatever, the fact is that Captain Simpson could not have believed that the waypoint was two full degrees of longitude west of McMurdo Station. It was obvious from the map used at the briefing that the distance was more than 20 miles, so when Captain Simpson saw himself going more than 20 miles left of track as he got to McMurdo Station, he would not have been the least bit surprised, would not have performed two updates, and would not have plotted the waypoint when he got home. In order to explain the surprise, but still advance ALPA’s case, you need a third location, in addition to the Dailey Islands waypoint and McMurdo Station. It needs to be west of McMurdo Station, but not by too much. This is when references to the Byrd Reporting Point start appearing. Captain Simpson made no such references in his initial statements. They started appearing after he started being “briefed” by ALPA’s lawyers.