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.

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