Day 007 - 06 Jul 94 - Page 36
1 square mileage) to see if you can help us to give an
estimate for the total area of timberland used for
2 McDonald's purposes throughout the world.
A. Okay.
3
Q. Do you accept, or not, that as a very rough guide to the
4 amount of packaging you need the number of restaurants per
country may assist?
5 A. Yes.
6 Q. Obviously, we leave out of account, if we use that figure,
the variation in the average number of customers that
7 visit those restaurants in those different countries?
A. We would.
8
Q. But, as a very rough guide, if there are, or were in 1993,
9 9,283 restaurants and those restaurants used a total of
9.4 square miles in that year, can we calculate that each
10 restaurant was responsible for using 0.0010126 square
miles?
11 A. You can.
12 Q. We know that Europe (which includes Africa and the Middle
East which is perhaps a strange concept, but it does for
13 these purposes) has 1,823 restaurants?
A. Okay.
14
Q. If we add the number of European restaurants to the number
15 of United States restaurants, that means that in 1993 the
rest of the world had 2,887 restaurants, 2887?
16 A. I follow.
17 Q. Would it be fair, when looking at those restaurants, for
the rest of the world to use what one might call the
18 American standard of number of square miles per restaurant
I have just suggested?
19 A. It would be fair.
20 Q. The European one actually works out rather lower?
A. It was a rough estimate.
21
Q. But let us use the higher figure, may we?
22 A. It is more conservative, yes.
23 Q. Then for those remaining restaurants in the world of 2887,
at a figure of point 0.0010126 square miles per
24 restaurant, one arrives, does one not, at a total area of
timberland used by those restaurants in the rest of the
25 world of 2.9 square miles total per annum?
A. Yes.
26
Q. In a sense, I am putting words into your mouth but have
27 you yourself done these calculations?
A. I have verified those calculations.
28
MR. JUSTICE BELL: If, in fact, we took the figures from the
29 tables and the premises you have accepted, we could sit
down and do it ourselves.
30
MR. RAMPTON: We could.
