Day 007 - 06 Jul 94 - Page 31


     
     1        A.  Yes.
 
     2   Q.   Two things about it:  First of all, the right hand column.
              You give percentages for the amount of recycled paper for
     3        each of those years?
              A.  Correct.
     4
         Q.   We notice that.
     5
         MR. JUSTICE BELL:   Just pause a moment, page 349.
     6
         MR. MORRIS:  For some reason we have completely different
     7        numbering on Helen's.  They are completely different
              numbers.
     8
         MR. JUSTICE BELL:  It has 13 written in longhand at the bottom
     9        or, rather, in manuscript.
 
    10   MR. RAMPTON:  You have given the percentage of recycled paper
              for each of these years-  1987 was 6 per cent; 1988 it was
    11        7 per cent; 1989 it was 7 per cent.  In 1991 it suddenly
              becomes 51 per cent?
    12        A.  Yes, it jumped quite dramatically.
 
    13   Q.   Can you make a stab at what the figure might have been in
              1990 from memory because it is missing, is it not?
    14        A.  I speculatively would make a stab.  It certainly is
              between 7 and 51 per cent, probably closer to the 50 per
    15        cent.
 
    16   Q.   You think it might have increased since 1989 above 7 per
              cent?
    17        A.  I think it would have.
 
    18   Q.   Can I ask you two questions about this:  First, do you
              know the reason why there was such a steep climb in the
    19        percentage of recycled paper between, let us say, 1989 and
              1991?
    20        A.  Yes, I do.  During that time, subsequent to 1989, it
              was identified that there was a landfill shortage in our
    21        country.  To try to increase the amounts of recycling
              activity, McDonald's felt, and Perseco felt, that if we
    22        purchased more recycled material that that would pull
              along the market for recycling.  So, we tried to increase
    23        our purchases of recycled materials.  That is, indeed,
              what we did.
    24
         Q.   I will not ask you; I will ask Mr. Langert that question.
    25        I will leave that on one side for the moment.  You notice
              also about this table that they believe that despite the 
    26        fact, as you told us, that McDonald's abandoned for many 
              purposes the polystyrene foam in favour of paper, yet the 
    27        total tonnage of paper used in 1991 in the left hand
              column, you see,  166,628 is not vastly greater than it
    28        was in 1989.  What is the reason for that, do you know?
              It leaps a bit in 1992?
    29        A.  It leaped a bit more than our typical growth and when
              we switched from foam to wraps, the weight did not
    30        significantly change.  The weights ----
 

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