Day 293 - 04 Nov 96 - Page 38
1 leaflet; and I do not think you contend that it does. It
2 has been shown.
3
4 MR. MORRIS: Well, first of all, I would say it does not say
5 about cutting down the forests; it says that is the area
6 needed to keep McDonald's supplied with paper; and that is
7 another argument. Secondly, even if you decided whatever
8 the meaning is, the reality is that it is still a fact that
9 McDonald's does require that amount of area of forest in
10 terms that I have identified in my figures here -- which
11 may even have been underestimates -- to maintain their
12 packaging supplies. That area of forest must be designated
13 as plantation forest for commercial production in order
14 that McDonald's can get their packaging. That is the
15 minimum area -- just as we are talking about the head of
16 cattle issue. So, whatever the interpretation of the
17 leaflet, it is still, we would say, relevant evidence in
18 this case -- which may or may not win the issue, but it is
19 still a relevant thing that we ought to all get our heads
20 around. We certainly say that it is basic common sense.
21
22 Obviously, I have calculated that to be a total of -- with
23 all those factorials, which are all quite basic common
24 sense and not overestimated, in some cases
25 underestimated -- something like 8,000 to 20,000 square
26 miles of forest are required to be available so that
27 McDonald's can get the kind of volume they need each year.
28 If that was reduced by the factor of point 7, if point 7
29 was removed, then it would be something like 200 square
30 miles. I am just trying to see. (Pause) That is not with
31 that additional point about "have only used some". Point 6
32 was clearly underestimated. So, it would be 200 times an
33 additional amount above the 1.4. It should have been, say,
34 1.8 or 1.9, if you count the whole of material not in
35 production -- which would be actually something like an
36 additional 28 percent, I think. So, it would be something
37 like 250 square miles.
38
39 MR. JUSTICE BELL: Yes. You have given me the material.
40 I understand your calculation. I will have to see what
41 I make of it when I have heard Mr. Rampton as well.
42
43 MR. MORRIS: Now, I think I may have a few other bits and
44 pieces.
45
46 MR. JUSTICE BELL: Shall we have a five-minute break there?
47 Ms. Steel can think if she wants to say anything or tell me
48 anything.
49
50 (Short Adjournment)
51
52 MR. MORRIS: Just on one point, on that page we were looking at
53 from Mr. Mallinson, where he says one thing at the top and
54 one thing at the bottom, we feel that the fact that he had
55 been in the frame of mind to look at it in a certain way,
56 and, obviously, being a McDonald's witness and someone who
57 was interested in defending the industry on this issue, we
58 think it is more significant what he said as at the top of
59 the page than what he said at the bottom of the page,
60 because that would be in some cases an admission against
