Day 056 - 28 Nov 94 - Page 40


     
     1        are not big enough to even be converted really into board
     2        material products like chip board and medium density fibre
     3        board.  Generally speaking (and this applies in different
     4        forests in different ways) the sawmill product, if there is
     5        an integrated industry, it is likely that the sawmill
     6        product waste will go to board materials and the thinning
     7        waste, in other words, the thinnings of the forest will go
     8        to pulp.  But it varies very, very much and it is very
     9        difficult to generalise.
    10
    11   Q.   I am sure it will get more confusing as we go along as
    12        well.
    13        A.  Unfortunately, yes.
    14
    15   MR. JUSTICE BELL:  It is clearly not just a question of how many
    16        square miles or whatever you need actually to chop down to
    17        produce so much packaging, but how it is replaced or
    18        replaces itself; there are all sorts of factors ---
    19        A.  Yes, my Lord.
    20
    21   Q.   -- at the end of the day?
    22        A.  I think the answer is along the lines of the way you
    23        are approaching it, that it is not a given square mileage
    24        that produces the product.  The important thing is that
    25        they are doing a thinning operation which is part of
    26        improving the forest, and that is actually improving
    27        ecologically as well as in growth terms, and they are doing
    28        a final clearing operation with a regeneration programme to
    29        follow.  So, that square mileage maybe significant in terms
    30        of this case, but it is not terribly significant in terms
    31        of good forest management.
    32
    33   Q.   Presumably, someone has asked you to do some square mileage
    34        sums because we have a square mileage figure in the
    35        leaflet?
    36        A.  That is correct, sir.
    37
    38   Q.   But were it not for that, that is not the way you would
    39        approach the question?
    40        A.  No, when we reach that point, sir.
    41
    42   Q.   Because it is more complicated?
    43        A.  Yes, it is more complicated.  When we do reach that
    44        point of actually looking at the area required to provide
    45        enough fibre to make packaging, what we will have to try to
    46        do is to compare what Mr. Kouchoukos did, approaching it in
    47        one way which is mathematical, and what I did which was
    48        assuming we were talking about how much area might be
    49        clearfelled as opposed to be part of a total Silvi cultural
    50        regime.  When we do reach that point, I would like to 
    51        respond, sir. 
    52 
    53   Q.   At some stage I think someone needs to go through it.  It
    54        may well be that Mr. Morris will do it in cross-examination
    55        so that I understand the way you have actually done your
    56        calculation and what it means.  I have read it more than
    57        once but I want to make sure I do understand it.
    58        A.  I have to say, sir, it does need further explanation.
    59
    60   MR. MORRIS:  So if you have a forest which they indicate has a

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