(10 pages) CAEPSG.20093.IP.19 [FESG NOx production cut-off].doc 

### COMMITTEE ON AVIATION ENVIRO NMENTAL PROTECTION (CAEP)

STEERING GROUP MEETING Salvador, Brazil, 22 to 26 June 2009 Agenda Item 3: Forecasting and Economic Analysis Support Group (FESG)

CAEP/6 NO X PRODUCTION CUT-OFF COST ANALYSIS (Presented by the FESG NO X Stringency Task Group)

SUMMARY This paper presents a high level estimate of the cost impact resulting from a production cut-off to the CAEP/6 NO X standard. The information presented in this paper builds upon the FESG assessment presented at the 2 nd CAEP Steering Group meeting 1 . The cost and the benefits are highly dependent on the way the production cut-off rule is implemented (with or without exemptions) and the response the one manufacturer will make in implementing this rule. If the engines affected are made compliant, FESG estimates non-recurring cost impacts of approximately $100 million, with some additional recurring costs. If the engines are not made compliant serious consequences will arise for the airlines that have aircraft in-service powered with these engines. They could be faced with operational problems and substantial costs due to the loss of r esale value. These are likely to result in overall costs of up to $1 B. Recent B777 aircraft from airlines of China, Japan, Korea and the United States could be affected under this scenario. Even though the analysis only provides broad orders of magnitude, FESG is of the view that sufficient information is gi ven to base a solid policy decision on.

1. INTRODUCTION

1.1 The purpose of ICAO NO X stringency requirements is to en sure that all newly developed airframes and engines incorporate th e latest commercially available proven technologies across the entire product line, mindful that no single technology can be applied across the entire fleet 2 . Unlike the CAEP/2 standard set to ensure new NO X reduction technologies were incorporat ed into new engine designs as well

1 Ref

. [CAEP-SG/20082-WP/06] “Production Cut-Off for Engine NO X standards”. Working paper subm itted at the second Steering Group meeting of the CAEP/8 cycle held in Sea ttle (United States) on September 22-26, 2008. 2 Ref

. [CAEP/7-IP/2] . “Report of the FESG Industry Respons e Task Group”. Information paper submitted at the CAEP/7 meeting held in

Montreal (Canada), from February 5 to 16, 2007. International Civil Aviation Organization



### WORKING PAPER CAEP-SG/20093-IP/19 02/06/09CAEP-SG/20093-IP/19 - 2 -

as in-production engines by a certain date, the CAEP/4 and CAEP/6 NO X standards did not mandate a production cut-off for non-compliant engines. The CAEP/4 decision was based on the limited number of engines affected at the date of implementation and th eir expected future market share. The decision made at CAEP/6 was based on evidence that market forces we re sufficient to bring non-compliant engines into compliance across the entire engine family.

1.2 Following the presentation of a working paper by the United States in November 2007 3 , the CAEP Steering Group directed WG3 and FESG to be gin work to assess a production cut-off for the CAEP/6 NO X standard at a date 4 and 6 years after the implementation date for newly certificated engines, 31 December 2007, such that it can be cons idered at the CAEP/8 meeting. This suggestion was predicated on the notion that mark et forces did not appear to be working and the only way to assure compliance of non-compliant engines was through the introduction of a production cut-off. In response to a paper presented by ICCAIA at the same meeting 4 , the Steering Group agreed to follow a step process to the assessment of a CAEP/6 productio n cut-off. They agreed that if sufficient evidence was produced to support the assertion that market forces had driven co mpliance then they would consider not continuing with a second phase to a full cost benefit assessment. Ho wever, if such evidence was not forthcoming, the Steering Group could decide to task FESG with a fu ll assessment of the effects of a CAEP/6 production cut-off.

1.3 Although both FESG 5 and WG3 6 were tasked to look into the i ssue, it was agreed that FESG take the lead on providing a qualitative analysis that woul d provide sufficient evidence that market forces have driven compliance of in-production engines with the CAEP/6 NO X standard.

1.4 At the second Steering Group meeting of the CAEP/8 cycle 7 , FESG presented a working paper 8 that provided detailed information on the status of th e list of engines that were labelled as “in-production” as of 2004 that did not meet the CAEP/6 standard . In summary, the FESG ass essment informed the Steering Group that all but 2 engine families curren tly in production had either already been made compliant or were nearing the end of a developmen t program to become compliant with the CAEP/6 NO X standard. FESG also presented data showing that th e 2 non-compliant engine families have very low volume of sales and will soon be out of productio n. The environmental benefit from implementing a production cut-off to the CAEP/6 NO X standard would be negligible , as 99+% of in-production engines sold will meet the CAEP/6 NO X requirements by 2009.

1.5 The information presented by FESG in this wo rking paper did not sufficiently address the concerns of some CAEP members and the Steering Group directed FESG to produce a report on the costs that would be attributed to a production cut-off. One CAEP member stated that if FESG was going to take on this additional task that the costs should be anal yzed and reported to present a detailed distributional analysis of costs by region, State and airline in a ddition to reporting the total cost impact. FESG reminded the Steering Group of the heavy workload it already ha d regarding the cost-effec tiveness analysis of the NO X stringency options under consideration for CAEP/8 and other CAEP analysis tasks. FESG agreed to conduct a scoping analysis of the process and data that would be required to complete the cost analysis of

3 Ref

. [CAEP-SG/20071-WP26 ]. “Production Cut-Off For CAEP/6 Engine NO X Standards”. Working paper subm itted by United States at the first Steering Group meeting of the CAEP/8 cycle he ld in Zurich (Switzerland) on November 26-30, 2007. 4 Ref

. [CAEP-SG/20071-WP27 ]. “Production Cut-Off For CAEP/6 Engine NO X Standards”. Informa tion paper submitted by the International

Coordinating Council of Aerospace Industrie s Associations (ICCAIA) in response to [CAEP-SG/20071-WP26]

. 5 Ref . FESG work programme for CAEP/8. Task F.08 “Conduct appropriate analysis on the projected number of engines that will not meet the

CAEP/6 NO X standards and reasons why any in-production engines remain non-compliant. The analysis should provide current and forecast sales as well as assessment of engines s till “in-production” as spares or new engines”. 6 Ref . WG3 work programme for CAEP/8. Task E.08.1.b) “Working with FESG, conduct appropriate analysis to assist decision making

regarding a CAEP/6 Production cut-off provision.” 7 Held in Seattle (United States) on September 22-26 2008. 8 Ref

. [CAEP-SG/20082-WP/06] “Production Cut-Off for Engine NO X standards”. Working paper subm itted at the second Steering Group meeting of the CAEP/8 cycle held in Sea ttle (United States) on September 22-26, 2008.CAEP-SG/20093-IP/19 - 3 -

the production cut-off, however, it would be given low pr iority due to the other tasks that were considered to be higher priority.

1.6 This paper provides information based on the anal ysis the FESG was able to do in the time available. The analysis provides some quantifica tion by making comparisons with previous analyses conducted by FESG. However given the fact that the production cut-off would affect only one manufacturer, more specific and de tailed information would be need ed to perform a comprehensive analysis. Given the resources and the time available, the analysis presented here is the best FESG could deliver, but it should provide sufficient information to inform a policy decision.

2. ENGINES IMPACTED BY PROPOSED PRODUCTION CUT-OFF

2.1 Summary of in-production engine models that will not meet the CAEP/6 NO X standard by 2009.

Engine Family Engine Model PW4x60 (PW4000

with 94inch fan) PW4056 Phase 3 * PW4060 Phase 3 * PW4062 Phase 3 *

PW4090 PW4074D PW4077D PW4084D PW4090

* TALON II combustor that is certified on PW4158

could be installed a nd certified on PW4056/60/62.

2.2 Table 1 in Appendix A provides an update to the projected delivery dates for the engine families listed in the table above.

2.3 Table 3 in Appendix A provides information on the in-service aircraft powered by the affected engines sorted by aircraft type, country of domicile and by airline.

3. COST IMPACT ANALYSIS

3.1 This proposal would only be directly applicable to newly manufactured aircraft engines inproduction at the time of the proposed production cut-off date that did not meet the CAEP/6 NO X standard requirements. The in-service aircraft engines would not be required to comply with the new (CAEP/6) NO X emissions standard at any future date. However th e costs and the methods to evaluate the proposal are highly dependent on the way the production cut-off is handled in practice.

3.2 The results will depend critically on whether or not exemptions are granted. Given the limited number of engines affected (22 plus possibly a number of spare replacements for the existing fleet), in the past for comparable numbers of engines, exemptions have been granted. If this was to be the case for the implementation of a production cut-off for CAEP/6 NO X standard then this measure would not result in any significant costs nor any environmental benefits.CAEP-SG/20093-IP/19 - 4 -

3.3 In the case where no exemptions are granted either fo r engines fitted to new aircraft or for spares, two sub-cases can be distinguished; one where the manuf acturer will take the necessary steps to make the engines concerned compliant and one where the decisi on is made not to on the grounds that it would not be a financially viable option.

3.4 The decision is made to bring the engines into compliance

3.4.1 The method used for the CAEP/6 NO X stringency cost-effectiveness analysis was employed to estimate the cost impact from a production cut-off to the CAEP/6 NO X standard. Both engine families listed in the above table would require a TL2 technology response. From the FESG CAEP/6 NO X stringency cost-effectiveness analysis 9 

### , a TL2 technology 10 

### response is where an engine manufacturer applies its best proven combustor technology, certified in at least one other engine family into another engine type, which would otherwise fail the proposed standard. A TL2 change requires modification and certification activities that are es timated to cost $50 million per engine family in 2002 dollars. For the CAEP/8 NO X 

### stringency analysis, ICCAIA has stated that the new MS2 technology response 11 

### is equivalent to the TL2 response and the non-recurring cost for the MS2 in 2008 dollars has been estimated at $50 to $75 million per engine family.

3.4.2 The total non-recurring cost for a CAEP/6 NO X production cut-off is therefore estimated to be between $100 and $150 million in 2008 dollars. The cost impact may be closer to the lower estimate of $100 million since one engine model of the PW4x60, the PW4158, had been certified with the TALON II combustor and is now compliant with the CAEP/6 NO X standard. However, there are still incremental certification analysis and tests that need to be perfo rmed for each model within the engine family. This cost impact would be incurred by one engine manufacturer. Estimated Non-Recurring Cost Impact = $100 million (2008 dollars) This means an additional cost (depending on the moment the production cut-off would be implemented) of more than $4 million (2008 dollars) per engine, with a resulting increase in the price of these engines if these costs are passed on to customers (e.g. airlines).

9 Ref

. [CAEP/6-WP/19] “Executive Summary of the Economic Analysis of NO X Stringency Options”. [CAEP/6-IP/13] “Economic Analysis of

NO X Stringency Options”. Papers submitted by FESG at the CAEP/6 meeting held in Montreal (Canada) on February 2-12, 2004. 10 TL2 – Technology Level 2. Five technology levels to achieve compliance were consider ed in the CAEP/6 analysis: TL1 to TL5 (th is latter

level being further subdivi ded in TL5A and TL5B). “ The technology level (TL) concept used in the CAEP/3 economic analysis of noise and emissions options was further developed and refined by WG3 based on actual and expected technologies available to manufacturers in the relevant time period. Specific TL are established on the basis of the nature of the technology change, and the effect on the co mbustor and engine design necessary for a non compliant engine to meet a given stringency option. The Fourth Steering Group Meeting endorse d the engine technology level matrix”. The TL definitions used in the ec onomic analysis was provided by WG 3. A TL2 level was defined as a

“ Major change with scaled proven technology . A change where known technology is applied within the exiting combustor envelope and is compatible with the engine thrust and pressure ratio characteri stics, and could be implemented w ithin the existing engine casin g. A full engine certification program and aircraft flight test w ould be required to prove airworthiness. Reductions with a major change might t ypically be in the 5 to 15 percent range.” Ref

. [CAEP/6-IP/13] “Economic Analysis of NO X Stringency Options”. Informatio n paper submitted by FESG at the CAEP/6 meeting held in Montreal (Canada) on February 2-12, 2004, section 3, starting on p.11. 11 MS2 – Modification Status 2: Scaled proven technology. The “Modification Status (MS)” methodol ogy for assessing engine technology

responses to the proposed CAEP/8 NO X stringency options includes Minor Changes (MS1) , Scaled Proven Technology (MS2) and New Technology (MS3). The approach is similar to that from CAEP/6, while avoiding the potential confusion between the use of the pr evious term “Technology Level (TL)” with the research orientated “Technology Readiness Level (TRL) ”. Ref

. [CAEP-SG/20082-WP/18] “NO X Stringency Technology Response Assessment”. Working paper presented by WG1 and WG3 at the second Steering Group meeting of the CAEP/8 cycle held in Seattle (United States) on Se ptember 22-26, 2008. Section 3, paragraph 3.1, p.2.CAEP-SG/20093-IP/19 - 5 -

3.4.3 There may also be some recurring costs impa cts from additional pr oduction and maintenance costs, but these are expected to be limited. Similarl y where the affected engines are made compliant, any losses of resale value should be limited.

3.5 The engines are not made compliant

3.5.1 The situation is very different in the case engi nes are not made compliant, as the recurring cost impacts would be much higher. The aircraft and airlin es that would be affected are given in Table 3 in Appendix A. This shows that there would be signifi cant impacts for B777 aircraft operated by airlines from China, Japan, South Korea and the United States.

3.5.2 If the engines mentioned in Table 1 in Appendix A are not made compliant and no exemptions are granted, the airlines that have aircraft in their in-service fleet powered by these engines are faced with a serious problem. First of all it would not be possible for them to acquire any new engines, with the risk of having aircraft out-of-service due to the inability to acquire spare engines to support the fleet. This risk becomes higher as the large fleets operated by a few carriers are sold and redeployed as smaller fleets to other carriers. If the new carriers operating smaller fleets are unable to acquire spare engines to be used as the installed engines are rotated th rough maintenance overhaul shops, then the risk of aircraft being outof-service becomes even larger. There are many operating costs associated with this type of event, such as lost revenue, costs associated with flight delays or even worse, flight cancellations. In the worst case it would mean cannibalisation of their existing aircraft . Furthermore it would become virtually impossible for them to sell their aircraft, with a significant loss of resale value.

3.5.3 If the implementation date for the production cut- off was before 2014, there would be significant costs to operators taking the remaining few deliveries of aircraft with the affected engines. There would be significant cost to the engine manufacturer of the affected engine as well in term of lost sales. The remaining aircraft to be delivered would have to ha ve alternative engines installed on the aircraft, which in turn, creates a commonality problem for these operators taking delivery of the remaining few aircraft. They would incur additional costs in the purchase of additional spare engines and incremental training costs.

3.5.4 The CAEP/6 analysis of NO X stringency included estimates of recurring cost impacts of the stringency options examined. As shown in Table 2 in Appendix A, these recurring costs were higher than the non-recurring costs by factors of between 4 and 9, depending on whether losses of resale value were included or not. In the case where the affected engi nes are not made compliant, FESG considers that a 9 fold factor would provide only a minimum estimate of these cost impacts.

4. LIMITATIONS TO COST ANALYSIS

4.1 Despite limited time and resources to devote to this task, FESG has been able to provide information on the in-service aircraft fleet that would be affected by a production cut-off. The distribution of the aircraft powered by the engines affected by this measure, shown in Table 3 in Appendix A, provides information on how these costs would be distri buted between airlines. FESG has also been able to quantify the non-recurring costs that would be incu rred by one engine manufacturer to respond to the production cut-off and bring these 2 e ngine families into compliance.

4.2 FESG could only produce a rough assessment of the recurring costs. There would also be incremental manufacturing costs for increased complex ity of design, if the engines were to be made compliant with the CAEP/6 NO X standard. Should the 2 engine fam ilies not be made compliant due toCAEP-SG/20093-IP/19 - 6 -

projected low sales volume, the incremental operating co st impacts to airlines having aircraft powered by the affected engines have not been analy zed. These costs include loss resale value.

4.3 In summary, the estimated non-recurring cost impact of making affected engines compliant with a production cut-off to the CAEP/6 NO X standard has been estimated to be approximately $100 million in 2008 dollars. In the event that the decision is made to bring the affected engines into compliance, recurring cost impacts would arise. A broad analysis of recurring costs, based on the analysis of the NO X stringency options performed for CAEP/6 suggests that these may be higher by factors of between 4 and 9, depending on whether loss of resale value is include d. In the case where airlines would not be able to acquire additional engines for spares, these costs coul d be significant, with serious implications for the continued operation and resale value of the affected ai rcraft. In these circumstances a 9 fold factor giving an overall cost impact of $900m provides a minimum estimate of these costs. At the same time the environmental benefits will remain so small that it has not been possible to qu antify them accurately.

– END –CAEP-SG/20093-IP/19 Appendix A A-1

APPENDIX A

Table 1 – Review of Orders for In-Product ion Engines That Do Not Meet the CAEP/6 NO X standards – Low Volume of Orders (Revised to update the pr ojected delivery dates)

Firm Order Backlog as of May 2009 – Number of Installed Engines

Engine Aircraft Total Backlog 2009 2010 2011 2012 2013 2014 2015

PW4062A 747-400F / -400ERF 8 4 4 PW4090 777-200 / -200ER 14 6 4 2 2 (Source : ACAS) 12

Table 2 – Comparison of Recurring to Non-Recurring Costs from CA EP/6 Cost-effectiveness Analysis

From CAEP/6 Cost-Effectiveness Analysis of NO X Stringency Options CAEP/4 – 10%: Mainly a TL2 technology response requirement Recurring Costs Ratio of Recurring to Non-Recurring Costs Discount

Rate NonRecurring Costs Without Lost Resale Value With Lost Resale Value Without Resale Value With Resale Value 0% $360 $2,607 $3,258 7.2 9.1 3% $324 $1,963 $2,508 6.1 7.7 7% $284 $1,386 $1,820 4.9 6.4 9% $267 $1,178 $1,566 4.4 5.9 Note : TL2 – Technology Level 2

12 ACAS – AirCraft Analytical System, by Reed Businesses Info rmation, is an aviation market information system database.CAEP-SG/20093-IP/19 Appendix A A-2

Table 3 – In-service Aircraft Fleets powered by PW4090 and PW4x60 Engine Families Data as of 1 April 2009

Number of Aircraft PW4090 PW4x60 Engine Family PW4x60 Grand Country Operator 777 747 767 A300-600 A310 MD11 Subtotal Total ARGENTINA AEROLINEAS AR GENTINAS 1 1 1 ARMENIA BLUE AIRWAYS (ARMENIA) 3 3 3 AUSTRIA AUSTRIAN 4 4 4 LAUDA AIR 2 2 2 BANGLADESH BIMAN BANGLADESH AIRLINES 2 2 2 BRAZIL OCEANAIR (BRAZIL) 2 2 2 VARIG - VRG LINHAS AEREAS 2 2 2 VARIG LOG 1 1 1 BRUNEI ROYAL BRUNEI AIRLINES 6 6 6 CAMEROON CAMEROON AIRLINES 1 1 1 CANADA AIR CANADA 7 7 7 CHILE CHILEAN AIR FORCE 1 1 1 LAN AIRLINES 4 4 4 CHINA AIR CHINA 10 12 7 19 29 AIR CHINA CARGO 5 5 5 CHINA CARGO AIRLINES 6 6 6 CHINA SOUTHERN AIRLINES 2 6 8 8 GRANDSTAR CARGO 1 1 1 GREAT WALL AIRLINES 4 4 4 HAINAN AIRLINES 3 3 3 SHANGHAI AIRLINES 7 7 7 CHINA, HONG KONG CATHAY PACIFIC AIRWAYS 16 16 16 DRAGONAIR 2 2 2 CHINA, MACAO AIR MACAU 2 2 2 VIVA MACAU 1 1 1 COLOMBIA AVIANCA 7 7 7 CZECH REPUBLIC CZECH AIRLINES 1 1 1 EGYPT EGYPTAIR 5 2 2 7 ETHIOPIA ETHIOPIAN AIRLINES 9 9 9 FIJI AIR PACIFIC 2 2 2 FRANCE CORSAIRFLY 6 6 6 GERMANY AIR CARGO GERMANY 1 1 1 CONDOR FLUGDIENST 9 9 9 ICELAND AIR ATLANTA ICELANDIC 1 2 3 3 AVION AIRCRAFT TRADING 1 1 1 ICELANDAIR 1 1 1 INDIA AIR INDIA 4 6 3 9 13 DECCAN CARGO 3 3 3 IRELAND AIRBUS FINANCIAL SERVICES 2 2 2 AWAS 1 1 1 ISRAEL EL AL ISRAEL AIRLINES 5 5 10 10 ITALY BLUE PANORAMA AIRLINES 4 4 4CAEP-SG/20093-IP/19 Appendix A A-3

Table 3 – In-service Aircraft Fleets powered by PW4090 and PW4x60 Engine Families Data as of 1 April 2009 – continued

Number of Aircraft PW4090 PW4x60 Engine Family PW4x60 Grand Country Operator 777 747 767 A300-600 A310 MD11 Subtotal Total JAPAN ALL NIPPON AIRWAYS 30 30 GALAXY A/L (JAPAN) (CSD OPS) 1 1 1 JAPAN AIR SELF DEFENCE FORCE 1 1 1 JAPAN AIRLINES INTERNATIONAL 22 22 22 44 LATVIA SMARTLYNX 2 2 2 LIBYA LIBYAN AIRLINES 2 2 2 LUXEMBOURG GLOBAL JET CONCEPT 1 1 1 MADAGASCAR AIR MADAGASCAR 2 2 2 MALAYSIA MALAYSIA AIRLINES 15 15 15 TRANSMILE AIR SERVICES 4 4 4 MEXICO AEROMEXICO 6 6 6 NETHERLANDS ARKEFLY 3 3 3 MARTINAIR HOLLAND 4 6 7 17 17 PAKISTAN PIA 6 6 6 PAPUA NEW GUINEA AIR NIUGINI 1 1 1 PORTUGAL EURO ATLANTIC AIRWAYS 1 1 1 SATA INTERNATIONAL 1 1 1 QATAR QATAR AIRWAYS 3 3 3 REUNION AIR AUSTRAL 3 3 ROMANIA TAROM 2 2 2 RUSSIA TRANSAERO AIRLINES 4 4 4 8 SAO TOME AND PRINCIPE STP AIRWAYS 1 1 1 SAUDI ARABIA ASASCO AVIATION 1 1 1 KINGDOM HOLDINGS 1 1 1 SAUDI ARABIAN VIP 1 1 1 SINGAPORE SINGAPORE AIRLINES 13 13 13 SINGAPORE AIRLINES CARGO 13 13 13 SOUTH KOREA ASIANA AIRLINES 10 10 KOREAN AIR 22 44 10 54 76 SPAIN AIR COMET 1 1 1 EADS CASA 1 1 1 PULLMANTUR AIR 3 3 3 SUDAN SUDAN AIRWAYS 3 3 3 SWITZERLAND BELAIR (SWITZERLAND) 1 1 1 TAIWAN CHINA AIRLINES 9 9 9 THAILAND ROYAL THAI AIR FORCE 1 1 1 THAI AIRWAYS INTERNATIONAL 13 13 13 UKRAINE AEROSVIT AIRLINES 4 4 4 UNITED ARAB EMIRATES DUBAI AIR WING 3 3 3 MAXIMUS AIR CARGO 2 2 2CAEP-SG/20093-IP/19 Appendix A A-4

Table 3 – In-service Aircraft Fleets powered by PW4090 and PW4x60 Engine Families Data as of 1 April 2009 – continued

Number of Aircraft PW4090 PW4x60 Engine Family PW4x60 Grand Country Operator 777 747 767 A300-600 A310 MD11 Subtotal Total UNITED STATES AIRCASTLE INVESTMENT 1 1 1 AIRCRAFT FINANCE TRUST 1 1 1 BOEING AIRCRAFT HOLDING CO 1 1 1 DELTA AIR LINES 35 35 35 EVERGREEN INTERNATIONAL 3 3 3 FEDERAL EXPRESS 26 19 18 63 63 GLOBAL PRINCIPAL FINANCE CO 2 2 2 GUGGENHEIM AVIATION INV FUND 1 1 1 HAWAIIAN AIRLINES 14 14 14 JT POWER LLC 1 1 1 MONTROSE GLOBAL CAPITAL 3 3 3 NORTHWEST AIRLINES 16 16 16 PALS 1 1 2 2 RYAN INTERNATIONAL AIRLINES 1 1 1 UNITED AIRLINES 52 30 35 65 117 UNITED PARCEL SERVICE 27 27 27 WELLS FARGO BANK NW NA TRUSTEE 2 2 2 WORLD AIRWAYS 2 11 13 13 UZBEKISTAN UZBEKIST AN AIRWAYS 5 3 8 8 VIETNAM VIETNAM AIRLINES 4 4 YEMEN YEMENIA 4 4 4 ZIMBABWE AIR ZIMBABWE 2 2 2 Grand Total 166 229 212 94 53 77 665 831