Day 239 - 23 Apr 96 - Page 29
1 there.
2
3 MS. STEEL: Just near the word "Para"?
4 A. Yes, it comes off near the word "Para" and then comes
5 right down there, and I was there in the headwaters of the
6 river and that is a dense, what is called "Terra Firme"
7 rainforest, containing everything you would expect to find
8 in a rainforest - your jaguars, your tapirs, your macaws,
9 your caimans and all the components as well as some
10 surviving groups of indigenous people.
11
12 Now, if I can just point out for the benefit of the court,
13 while there is this fantastic complexity of rainforest
14 types throughout the Amazon they can basically be divided
15 into three broad tranches. There is the rainforest along
16 the flood plains of what are called the whitewater rivers
17 which carry a high sediment load which, in Brazil, is
18 called "Varsia". There is the rainforest along the clear
19 or blackwater forests in their flood plain which has a low
20 sediment load, like the Rio Negro, and that is called
21 "Igapo".
22
23 Q. Where is that?
24 A. The Rio Negro comes down to Manaus here, and that is
25 just an example, but there are several clear water rivers
26 which are surrounded by Igapo. Then there is all the
27 rainforest on a slightly higher ground, i.e. which is not
28 in the flood plains which is called "terra firme" and
29 "terra firme" embraces a huge number of rainforest types,
30 as I say, but it is undeniably part of the Amazon Basin's
31 rainforest. That is the "terra firme" forest. It is a
32 bulk of the Amazon Basin's rainforest and you can see it
33 here, here and here. All of that area -----
34
35 Q. Sorry, just say which part?
36 A. We are talking about the -- these broad swathes along
37 here.
38
39 Q. That is the green and the light blue, is it?
40 A. It would incorporate a lot of that light blue. Again,
41 as I say, it is fantastically complex. There is no clear
42 margin. But if we can draw a broad swathe along the
43 southern part of the basin that is "terra firme forest".
44 If we draw a broad swathe up here along the northern part
45 and around here in the Bahia de Charco up here, you will
46 see that that is also terra firme forest.
47
48 MR. JUSTICE BELL: What are we doing up there anyway,
49 Mr. Morris? It must be about 3,000 miles from anything
50 which has cropped up in this case. It could be 6,000, for
51 all I know.
52
53 MR. MORRIS: I know.
54
55 THE WITNESS: I am sorry, my Lord. The point here I was trying
56 to make, with apologies -----
57
58 MR. JUSTICE BELL: No, it is not for you to make points, I am
59 afraid. It is for Mr. Morris to ask you questions which it
60 is relevant for me to hear. That is not a rebuke to you,
