Day 293 - 04 Nov 96 - Page 32
1 statement, which Mr. Mallinson relied on, which we have now
2 all got copies of hopefully. Right. That is my
3 references. Bearing all that in mind, can I say actually,
4 that the second page, the document which I showed that
5 people could not find, that Mrs. Brinley-Codd had given me,
6 well that would be page 2 of the one that you handed to me,
7 Terence Mallinson, the letter from Mr. Thompson, the third
8 page of it was not there but you had all three pages. So
9 what there are in terms of documents are the ones that is
10 the conversion factors for calculation of forest areas,
11 then there was the letter to Terence Mallinson from Donald
12 Thompson that Mr. Mallinson relied on, which is two pages,
13 and then the second page of what I handed up was a document
14 which was some kind of trade journal which identified how
15 much carton board came into the Igessund mill. That should
16 be page 2 of that.
17
18 MR. JUSTICE BELL: Yes, I have that. I am just going to put
19 that behind the Thompson conversion factors, in turn behind
20 Mr. Mallinson's November 1994 statement.
21
22 MR. MORRIS: Yes, because if you look at the Igessund's bottom
23 left-hand box, it shows the raw material intake into
24 Igessunds. 267,000 cubic metres of small round wood, plus
25 sawmill soft wood residues, about an extra 10 percent, and
26 about half of that from the production output is about half
27 of the total, can you see it, 152,000 tons. So in reality,
28 to get 150,000 tons of carton boards, you have to have as
29 near as makes no difference double the amount at the
30 beginning. (Pause)
31
32 before I go through my chart I am going to go to the
33 statement of Mr. Kouchoucos. It might be helpful to dig
34 that out, if we can find it. I don't know where it would
35 be, actually. Recycling and waste. Yellow. Recycling and
36 waste witnesses.
37
38 MR. JUSTICE BELL: Well, it is in yellow 3.
39
40 MR. MORRIS: Right. It is his first statement and it is page 3
41 of his statement, paragraph 7. What I have done is, I have
42 taken his calculation at face value on the grounds that it
43 is something solid that we can all work on. And what
44 I have done is, he says in 1992 McDonald's consumed 180,000
45 tons of paper, which of course, as we now know, is not the
46 full figure. So something should be added on there. That
47 would be covered by point 5 of my handwritten ----
48
49 MR. JUSTICE BELL: Yes.
50
51 MR. MORRIS: In point 5 of my calculations, I am talking about
52 you have to add on all the non-Persico packaging, including
53 transport packaging for food, office supplies, promotional
54 material, toilet rolls, kitchen towels, all that kind of
55 stuff. Then he says that 51 percent was made from recycled
56 paper, so that could be discounted. As we have heard at
57 the relevant time in this case, the volume of recycled
58 content was very small and of that recycled content, that
59 an even smaller part of it was actually post-customer
60 recycling, even including their calling McDonald's a
