Day 007 - 06 Jul 94 - Page 30


     
     1        taking the second and third lines together.  I had assumed
              that you had assumed that all McDonald's packaging
     2        purchased in that year was discarded into the municipal
              solid waste stream for the purposes of your exercise?
     3        A.  Correct.
 
     4   MR. RAMPTON:  So, does it follow from that that what we are
              looking at here is what is nowadays called a worst case
     5        scenario?
              A.  Yes, if it is discarded into the solid waste stream in
     6        the US we meanthat it could be recycled; it could be
              incinerated; it could be put in a landfill.
     7
         Q.   So far as waste is concerned, it is the maximum; is that
     8        right?
              A.  Correct, yes.
     9
         Q.   The figure I am interested in is the one which is a total-
    10        total paper based packaging, 181,639 tonnes.  An American
              tonne is not the same as a British or a metric tonne?
    11        A.  Apparently not.  An American tonne is 2,000lbs or a
              short tonne, apparently.
    12
 
    13   MR. JUSTICE BELL:   Whereas ours is 2,240, presumably?
              A.  Correct.
    14
         MR. RAMPTON:  Which I am told, my Lord, is the equivalent of a
    15        metric tonne.
 
    16   MR. JUSTICE BELL:   Because there are 2.2 lbs in a kilo, so it
              comes out virtually the same.
    17
         MR. RAMPTON:  Virtually the same.  Keeping that figure in your
    18        head (though I am sure it is engraved anyway), 181,639
              short tonnes total, I would like you to turn to the back
    19        of this file to the tab where we find the exhibits to your
              second statement?
    20        A.  Okay.
 
    21   Q.   Page 349, it is stamped at the bottom of the page.
              A.  Okay.
    22
         Q.   All right?
    23        A.  Yes.
 
    24   Q.   Here we see a document which gives, as it were, a
              breakdown of the kind of paper or its source, for a number
    25        of years, 1987, not through 1992, because 1990 is missing,
              is it not? 
    26        A.  Correct. 
  
    27   Q.   I am interested in the percentages in the right hand
              column. First of all, this says it is produced by Perseco,
    28        David Kouchoukos, Environmental Affairs Manager. Can we
              make the same assumptions about this document as the one
    29        we were looking at before?
              A.  Yes.
    30
         Q.   It is a piece of homework by you?

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