Day 007 - 06 Jul 94 - Page 78


     
     1   Q.   But in 1989, for example, virtually all the paper used was
              not recycled, yes, we are talking about 6 per cent?
     2        A.  Yes, figures of 6 and 7 per cent for those years.
 
     3   Q.   In other words, the figure that was finally established,
              whatever the calculations, of 9 square miles, is going to
     4        be at least somewhere around half of the figure if there
              was no recycled content?
     5        A.  So, if the allegation would be made that 100 per cent
              of 181,000 would take 18 square miles, then I guess that
     6        would be correct.
 
     7   Q.   Something like that.
              A.  But we did not use that much paper packaging in 1987
     8        or 1988.
 
     9   Q.   No, it was slightly lower.  It was something like 150,000
              tonnes?
    10        A.  Yes, it would have been proportionately lower.
 
    11   MR. JUSTICE BELL:  You have the figures there and we can start
              to do our arithmetic again with selecting the figures for
    12        any given year.
 
    13   MR. MORRIS:  Yes.
 
    14   MR. JUSTICE BELL:  If we went back two or three years we would
              find far less recycled paper, but then we would find far
    15        less paper anyway.  We could work out what effect that had
              on square miles, assuming your approach is a valid one?
    16        A.  We could.
 
    17   MR. MORRIS:  Is it true, though, that at every stage in the
              process from chopping down a tree to final packaging in
    18        McDonald's stores, that there is lossage and wastage at
              all stages?
    19        A.  That is why when I quantified I did not look at
              trees.  I looked at the volume of pulp that comes off of a
    20        given acre and that accounted for all the losses.  The US
              DA says that you will get X tonnes of pulp from a given --
    21        they are the figures we presented.
 
    22   Q.   Yes, but pulp surely turned into packaging has to be
              refined, moulded and cut?
    23        A.  Hundred per cent yield, 99.9 per cent yield of the
              pulp to paper packaging; industrial recycling of the trim
    24        scrap is 100 per cent efficient.  It is a valuable raw
              material they are not going to throw away.
    25
         Q.   I do not know.  I mean, we were under the impression that 
    26        there is such a thing as post-industrial waste that may be 
              reused.  We do not know if they calculate that in their 
    27        figures, do we?
              A.  No.  The US DA has figures here showing how much paper
    28        you will get from a given acreage.  That is the figures
              I used.
    29
         Q.   We do not know if they calculate post-industrial waste and
    30        whether that is taken into consideration?
              A.  It would have to be.

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