Day 239 - 23 Apr 96 - Page 24


     
     1        deforested between 1940 and 1982 and, obviously, there may
     2        have been deforestation since 1982 not marked on the map.
     3        Because it is easier to compare a map to a map rather than
     4        describe where you are pointing at with your fingers, does
     5        that or does that not accord with your view on the extent
     6        of what might be described as tropical rainforests?
     7        A.   This map here, the small one?
     8
     9   Q.   Yes.
    10        A.  Yes.
    11
    12   Q.   I mean, obviously, you have said that there are still
    13        stands of rainforest outside what, traditionally, might be
    14        called tropical rainforest areas etc. etc, but as a rough
    15        guide is that helpful or not helpful?
    16        A.  I would say broadly, yes, that would more or less
    17        correspond with what I would consider to be tropical
    18        rainforest, this small map.
    19
    20   Q.   Right.
    21        A.   But, of course, it is difficult to draw hard and fast
    22        lines, as I say, and I think one thing I would like to
    23        point out is there is this phenomenon which the Kaoiwa
    24        Indians call -- they have a name for it, "Apete" --
    25        A-P-E-T-E, which are these outliers of rainforest extending
    26        sometimes several hundred miles south of what would be the
    27        sort of main block of the rainforest and they are familiar
    28        with these because they use them for their long distance
    29        hunting, foraging, migrations which can sometimes persist
    30        for a whole year.
    31
    32   Q.   If we look at particular states, for example, such as Mato
    33        Grosso do Sul?
    34        A.   Yes.
    35
    36   Q.   Can you just identify in that state the forest types and
    37        the vegetation types.  Is there tropical forest in that
    38        state?
    39        A.   Well, there is certainly a lot of what is called here
    40        dense woodland.  There is -----
    41
    42   Q.   Which colour is that?
    43        A.   That is the dark pink.
    44
    45   Q.   Right.
    46        A.   And it is on the key.  It says "Arborea Densa", which
    47        translates roughly as dense woodland.  Then there is the
    48        open woodland and then this SN, savanna or seasonal
    49        forest.  I just want to check what ST is -- savanna or step
    50        type savanna -- and here we have also these ----- 
    51 
    52   MR. JUSTICE BELL:   Where are we going?  Just pause a moment. 
    53        A.   I am sorry.
    54
    55   MR. MORRIS:  I was trying to -- I thought the best approach was
    56        to look at the particular states and say -----
    57
    58   MR. JUSTICE BELL:   I do not think it is helpful just to look at
    59        particular states and say what vegetation there is in those
    60        states.  If we start from square one.  Insofar as at the

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