Day 293 - 04 Nov 96 - Page 33
1 customer of their transport packaging.
2
3 So effectively, you have to add another factor which is the
4 point 4 of my calculations, which are to recognise that
5 I have given them a healthy 15 percent recycled content for
6 the relevant year on the grounds that that is the maximum
7 figure that McDonald's could claim but I would say it was
8 less, especially when you consider post-customer waste. So
9 that would give the figure of 1.7. You would have to
10 multiply what he has got there by 1.7 to get not 50 percent
11 of their volume, virgin paper, but 85 percent. So if you
12 multiply by 1.7... I have an A level in mathematics but
13 I do not claim to be the best mathematician in the world.
14 I have calculated the non-Persico packaging in point 5, as
15 may be, on a world scale, a third of the packaging omitted
16 by volume in their calculations. If a third is missing,
17 they have only got two thirds of the figure, then you would
18 have to multiply by 1.5 to get the full figure. Does
19 that ----
20
21 MR. JUSTICE BELL: I understand what you are saying.
22
23 MR. MORRIS: Right. Now, going back to Mr. Kouchoucos'
24 statement, he then goes on in paragraph 8 to say it takes
25 117 cubic feet of trees to make one ton of paper or paper
26 board. I am not particularly happy with that calculation,
27 but I am trying to base it on his calculations so that we
28 have some ground we can share in common. And that would
29 not include all the loss in the whole industrial process,
30 et cetera.
31
32 Then we go to point 9. Based on his calculation 14.7 tons
33 of paper or paper board can be made from one acre of
34 timberland per year. Obviously, the point I am making is
35 that it is not, it is only part of what is produced and
36 there is also sawn wood, et cetera, as well. Then this is
37 the important one, we get to paragraph 10. His conclusion
38 is that something like nine and a half square miles of
39 timberland is needed for McDonald's US packaging. But that
40 is not considering a sustainable yield or an area of forest
41 that would be needed to get that kind of volume of timber.
42 So I have started off with bearing in mind that 9.4 square
43 miles - he said that their restaurants are about 70
44 percent, are in the USA, or were at that time. But my
45 understanding is that certainly their volume abroad has
46 increased and their percentage abroad has increased; and
47 secondly, the volume is greater, we have heard. I can't
48 remember which witness said it, but the volume is greater
49 outside of America per store.
50
51 So bearing that in mind, I calculated 20 square miles,
52 because he said even if the amount of paper board
53 consumption were doubled to take into account the rest of
54 the world, which is unlikely to be the case, it can be seen
55 that the allegations are totally unfounded. So I took him
56 at his word and said, let us double it, and maybe I should
57 have stuck to 18, but it was easier to make the
58 calculations based on the same figure.
59
60 MR. JUSTICE BELL: Why did you double it; say that again?
