Day 007 - 06 Jul 94 - Page 58


     
     1
              Well, the rate at which McDonald's consumes Formacel-S at
     2        that point in time annually would have continued to be the
              same rate.  It is not based on any sales there, so I
     3        cannot make that argument, can I?  There may be some form
              of that argue which I could recalculate.
     4
         Q.   Do not bother with it now, but what these tables are doing
     5        is showing the rate at which McDonald's created a market
              for CFCs or HCFCs compared with the creation of other
     6        markets?
              A.  Other consumptions.
     7
         MISS STEEL:  Just to go back to page 34 -- sorry, before we do
     8        that, I would make the same point in relation to car air
              conditioners.  Generally, people do not buy a new car
     9        every year?
              A.  Yes.
    10
         MR. JUSTICE BELL:  Yes, I think you have accepted that to some
    11        extent?
              A.  That is the point that his Lordship was making, yes.
    12
         MISS STEEL:  Right, then to go back to page 34.  On the first
    13        line you have the volume of CFCs and HCFCs produced?
              A.  Yes.
    14
         Q.   Based on the 1987 figures?
    15        A.  Yes.
 
    16   Q.   Was there a reason why you used 1987 figures?
              A.  Those were probably the most recent available at that
    17        point in time.
 
    18   Q.   Right.  You have told us that in August 1987, I think it
              was, McDonald's started the trend which you say the rest
    19        of the industry followed for phasing out CFCs and
              replacing them with HCFCs?
    20        A.  We made an announcement of our plans to do so.
 
    21   Q.   And that was around the time that the Montreal Protocol
              was coming?
    22        A.  Just prior.
 
    23   Q.   So, generally speaking, this was the time when people were
              becoming concerned about the issue and were beginning to
    24        look for alternatives, starting to use alternatives?
              A.  I do not know if the general public was aware.
    25
         Q.   But the people who use blowing agents and CFCs and HCFCs? 
    26        A.  Yes, scientists that we relied upon for information. 
              That is when they did start becoming aware and they were 
    27        beginning to inform us.
 
    28   Q.   So the figures would have dropped from 1987?
              A.  To when?
    29
         Q.   They would have dropped throughout 1988?
    30        A.  They could have shifted, maybe everything went and I
              do not know because I did not track it, but another

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