Day 007 - 06 Jul 94 - Page 37
1
MR. JUSTICE BELL: This is a very convenient way of having it
2 done for one, but so that the defendants hear (in case it
is not obvious) this witness is doing the arithmetic for
3 us which we could do ourselves.
4 MR. RAMPTON: It is only so that we can get it on the
transcript, and so one can have a very rough figure for
5 the total square mileage of timberland used by McDonald's
annually throughout the world. If it is 9.4 in the United
6 States, and 1.3 in Europe and 2.9 in the rest of the
world, we get a total of 13.6 square miles per annum?
7 A. That would follow, yes.
8 Q. Having, as it were, looked at or verified that last
exercise we have just done, Mr. Kouchoukos, does it seem
9 to you that what we have come up with is a fair figure?
An exagerration? Or a gross under estimate?
10 A. I think it is very fair figure, probably on the high
side.
11
Q. Why do you think it might be on the high side?
12 A. Because in the numbers that I calculated I used all
trees, all types, all types of pulping processes, and in
13 fact the pulping processes that are dominant in the
packaging industry are more efficient than what is stated
14 as the overall average. So, it is a conservative
estimate.
15
Q. If you use acreage or square mileage you under- estimate
16 --- You might be under- estimating the density of the
trees in each square mile?
17 A. That is correct, especially in a pine plantation or
where the trees are closer.
18
Q. Do you distinguish (and this is not really a question for
19 you) in point of density between a natural forest and one
which is grown for commercial reasons?
20 A. You can distinguish. I did not distinguish the
differences in my estimate, no.
21
Q. Would a plantation forest generally, do you know, be
22 denser than a natural forest?
A. I would certainly expect so, yes.
23
Q. There are two more things I would like to ask you about;
24 The first is, going back now to just the United States,
where the trees come from which are used for McDonald's
25 paper ---- Do you still have the yellow file?
A. I have.
26
Q. Can you go to the back of it which is divider four, and
27 your second statement?
A. Okay.
28
Q. Is the first document in that ---- Mine has a handwritten
29 2 on it. Is it a table of headed 'Perseco/McDonald's
Supplier Pulp Bleaching Summary'?
30 A. That would be 3 pages back, 338.
