Day 293 - 04 Nov 96 - Page 34
1
2 MR. MORRIS: He said in his paragraph 10 that ----
3
4 MR. JUSTICE BELL: You are doubling it to get worldwide?
5
6 MR. MORRIS: To get worldwide usage, yes. I am prepared to
7 concede that it might be helpful to start off with a 19
8 square miles figure rather than 20, which is strictly
9 doubling 9.4. Now, having got his figure ----
10
11 MR. JUSTICE BELL: Carry on, but, I mean, the whole of your case
12 is his figures are totally nonsense anyway.
13
14 MR. MORRIS: Not strictly, because taking that as an admission,
15 that not counting recycled content, not counting material
16 lost in production, not counting a number of factors, it
17 would be not counting the area needed, in reality, of
18 forest needed for that kind of amount of cubic feet, cubic
19 metres. We could start off with the 9.4 and in fact double
20 it to a world level and then do the calculation factorials
21 on top of that. So the reality is that take into account,
22 like number one in my chart, starting with 20, but I will
23 accept this could be out by 5 percent, one, 10 percent is
24 left in the forest. So in terms of physical cubic volume
25 in the forest only 90 percent is available. So you would
26 have to ----
27
28 MR. JUSTICE BELL: Yes, I understand.
29
30 MR. MORRIS: Multiply by 1.1. Two. Now the pulp wood, this
31 was relying on Mr. Mallinson's agreement with
32 Mr. Thompson's point, which in his chart pulp wood is only
33 40 percent of the total used.
34
35 MR. JUSTICE BELL: That is 178 against 254, is it?
36
37 MR. MORRIS: Yes, 178 of 480 -- let me have a look. (Pause) It
38 is 178 of the total produced, which is 178 plus 254.
39 Because I have already deducted the 10 percent left in the
40 forest.
41
42 MR. JUSTICE BELL: Yes. 432.
43
44 MR. MORRIS: Yes. I will use that as approximately 40
45 percent. So in order to - whereas McDonald's figures are
46 considering it is hundred percent used for their purposes,
47 in fact it is only 40 used for their purposes, in which
48 case you would have to multiply it by 2.5.
49
50 MR. JUSTICE BELL: Yes. Then you have allowed 10 percent, not
51 15 percent?
52
53 MR. MORRIS: Yes. I was being very generous there, it could be
54 15 percent, but if it was 15 percent, it would not be 1.15
55 percent calculation, because it would be certain
56 mathematics involved there - it is hard to explain. But
57 just like, yes...
58
59 MR. JUSTICE BELL: Anyway, I understand what you are doing.
60
