Day 293 - 04 Nov 96 - Page 33


     
     1        customer of their transport packaging.
     2
     3        So effectively, you have to add another factor which is the
     4        point 4 of my calculations, which are to recognise that
     5        I have given them a healthy 15 percent recycled content for
     6        the relevant year on the grounds that that is the maximum
     7        figure that McDonald's could claim but I would say it was
     8        less, especially when you consider post-customer waste.  So
     9        that would give the figure of 1.7.  You would have to
    10        multiply what he has got there by 1.7 to get not 50 percent
    11        of their volume, virgin paper, but 85 percent.  So if you
    12        multiply by 1.7...  I have an A level in mathematics but
    13        I do not claim to be the best mathematician in the world.
    14        I have calculated the non-Persico packaging in point 5, as
    15        may be, on a world scale, a third of the packaging omitted
    16        by volume in their calculations.  If a third is missing,
    17        they have only got two thirds of the figure, then you would
    18        have to multiply by 1.5 to get the full figure.  Does
    19        that ----
    20
    21   MR. JUSTICE BELL:   I understand what you are saying.
    22
    23   MR. MORRIS:   Right.  Now, going back to Mr. Kouchoucos'
    24        statement, he then goes on in paragraph 8 to say it takes
    25        117 cubic feet of trees to make one ton of paper or paper
    26        board.  I am not particularly happy with that calculation,
    27        but I am trying to base it on his calculations so that we
    28        have some ground we can share in common.  And that would
    29        not include all the loss in the whole industrial process,
    30        et cetera.
    31
    32        Then we go to point 9.  Based on his calculation 14.7 tons
    33        of paper or paper board can be made from one acre of
    34        timberland per year.  Obviously, the point I am making is
    35        that it is not, it is only part of what is produced and
    36        there is also sawn wood, et cetera, as well.  Then this is
    37        the important one, we get to paragraph 10.  His conclusion
    38        is that something like nine and a half square miles of
    39        timberland is needed for McDonald's US packaging.  But that
    40        is not considering a sustainable yield or an area of forest
    41        that would be needed to get that kind of volume of timber.
    42        So I have started off with bearing in mind that 9.4 square
    43        miles - he said that their restaurants are about 70
    44        percent, are in the USA, or were at that time.  But my
    45        understanding is that certainly their volume abroad has
    46        increased and their percentage abroad has increased; and
    47        secondly, the volume is greater, we have heard.  I can't
    48        remember which witness said it, but the volume is greater
    49        outside of America per store.
    50 
    51        So bearing that in mind, I calculated 20 square miles, 
    52        because he said even if the amount of paper board 
    53        consumption were doubled to take into account the rest of
    54        the world, which is unlikely to be the case, it can be seen
    55        that the allegations are totally unfounded.  So I took him
    56        at his word and said, let us double it, and maybe I should
    57        have stuck to 18, but it was easier to make the
    58        calculations based on the same figure.
    59
    60   MR. JUSTICE BELL:  Why did you double it; say that again?

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