Day 056 - 28 Nov 94 - Page 49
1 with is that it has gone in because his statement has gone
2 in. I do not think you will be doing yourself any harm by
3 sticking to the main points and putting your challenge to
4 them pretty directly. That is really what I am saying.
5
6 MR. MORRIS: Yes, as far as I understood it, it was Mr. Bateman
7 that was meant to be responding to Ms. Carroll anyway.
8
9 MR. RAMPTON: No. My Lord, if necessary, I can remind your
10 Lordship of the passage.
11
12 MR. JUSTICE BELL: Mr. Bateman responded to some of it.
13
14 MR. RAMPTON: Ms. Carroll said that as well as soil erosion
15 there is usually an absence of natural diverse ecosystems,
16 so on and so forth.
17
18 MR. MORRIS: That has been dealt with by Mr. Hopkins.
19
20 MR. JUSTICE BELL: Just bear in mind what I have said.
21
22 MR. MORRIS: I will ask you some questions about the
23 calculations. I will be quite plan with you that I do not
24 actually understand all the methodology and details, but on
25 page 4 at the bottom it is talking about "some imported
26 hardwood market pulp is added". What do you mean by that,
27 at the very bottom, the last sentence? Is that in addition
28 to the ----
29 A. Yes, I think in the case of the example given here, the
30 imported hardwood market pulp is the furnish on the very
31 surface of certain products in packaging which need to have
32 a protective layer to them and give it, then there is an
33 element of hardwood pulp in them, which in the case of
34 Southern Scotland providing to the particular mill with
35 which they were dealing (which was the Iggesund mill) would
36 have been imported. So it is merely a statement that in
37 their case they would have used that. In another mill's
38 case like Enso-Guzeit Oy it would not be necessary for them
39 to import it because they have got it.
40
41 Q. Do you happen to know what the volume of that imported
42 hardwood would have been?
43 A. It is so insignificant in this that my source
44 information on this -- this was a calculation done in fact
45 rather than one in theory -- it was insignificant.
46
47 Q. But it was important for the finish of the paper product?
48 A. The point was, we made the point that that might have
49 been imported because not to do so would have been
50 incorrect.
51
52 Q. Do you happen to know where that hardwood was imported from
53 or generally is imported from?
54 A. No.
55
56 MR. JUSTICE BELL: Do you know what kind of hardwood it was?
57 A. No, I do not, but on a presumption one would have
58 suggested it could well have been birch and could have well
59 have been from Scandinavia, because pulp from Scandinavia,
60 including birch pulp, is imported.
