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Comment on the Meander Dam proposal
 

Does the Proposed Meander Dam comply with Tasmania's obligations for new rural Infrastructure development under COAG's Water Reform Framework?

Prepared by: Tony Trujillo WWF Australia March 2003

Executive Summary
The Meander Dam is proposed to be constructed on the Meander River in Tasmania. It is estimated to cost of $27 million and will hold 43,000 ML of water. It is intended principally to provide water for irrigation, with the ability to supply 24,000 ML per year for this purpose.

The State’s Resource Management and Planning Appeal Tribunal overturned the construction permit for the dam on environmental grounds. The Tasmanian Government has now signalled the intention to introduce legislation that will allow construction of the dam despite the ruling by the Tribunal.

As part COAG’s Water Reform Framework, States have agreed undertake certain obligations. With reference to the proposed Meander Dam, the State’s obligation is to undertake construction of the dam ‘…only when appraisal indicates it is economically viable and ecologically sustainable’. In addition, States are obligated to price water so that all costs are recovered.

The intention of this paper is to determine whether the proposed Meander Dam will meet its COAG obligations. WWF Australia will focus on determining whether the Project meets COAG’s economic requirements. This is not to diminish the importance of the ecological impact of the project but rather to not duplicate the analysis prepared by other organisations such as The Tasmanian Conservation Trust on the environmental impacts of the dam.

Proponents for the construction of the Meander Dam have commissioned consultants to prepare two documents providing the economic justification for the dam. Information contained in these documents and the supporting surveys were used by WWF to assess whether the proposed dam will meet the COAG economic commitments.

On the evidence provided, WWF concludes that the project is not commercially viable and therefore will not meet COAG requirements specified in clause 3(d) (iii):

  • The Net Present Value of the project was assessed at between negative $16 million and $13 million. If environmental costs were included this would be a larger loss.
  • There is no justification for the government subsidising construction of the dam based it providing public benefits. Although some public benefits with a Net Present Value of $2 million were identified by the consultants, no costs to the public (environmental, third party) were included.

WWF considers that full costs will not be recovered at the proposed price of $55/ML. There does not appear to be scope for increasing the price, since any price above this level has been demonstrated to reduce demand and total project revenue. Therefore the project will not meet COAG obligations defined in clause 3(d)(i.).

Introduction
The Tasmanian Department of Primary Industries Water and Environment (DPIWE) is proposing construction of a dam on the Meander River primarily for the extraction of irrigation water. A Feasibility Study and a Draft Economic Evaluation have been prepared for the dam’s proponents detailing the expected costs to be incurred and benefits to be provided by the dam. The Council of Australian Governments (COAG) Water Reform Framework specifies obligations agreed to by each state for construction of new rural infrastructure and pricing of water. These form part of the National Competition Policy (NCP). Conformance to this policy is assessed annually by the National Competition Council (The Council).

The intention of this paper is to determine whether the Proposed Meander Dam will meet its COAG obligations based on the information provided by the proponents.

Background
The Meander Dam is proposed to be constructed on the Meander River in Tasmania at the southern end of the Meander Gorge at a cost of $27 million. It will contain 43,000 ML of water, stand 48 metres high and 170 meters wide, and flood an area of 332 hectares. It is intended principally to provide water for irrigation, with the ability to supply 24,000 ML per year for this purpose. It also includes a mini hydroelectric power plant with the capacity to provide 10,000 MWh of electricity per annum.

The dam has been designated a controlled action under the Commonwealth Environmental Protection and Biodiversity Conservation Act 1999. Under the statutory process of Tasmania’s Water Management Act and Environmental Management and Pollution Control Act, a permit was issued in October 2002 for construction of the dam. In January 2003, issue of the permit was overturned following an appeal to the Resource Management and Planning Appeal Tribunal. The Tasmanian Government currently plans to introduce legislation that will allow construction of the dam despite the ruling by the Tribunal (Green (2003)).

COAG Obligations
In 1994 the Council of Australian Governments agreed a Water Reform Framework. States accepted an obligation to meet the requirements defined under the agreed Framework. In relation to the Meander Dam proposal, these obligations relate to the construction of new rural infrastructure, and pricing of water so that the all costs are recovered.

States have agreed under clause 3(d)(iii) of the COAG framework that in relation to rural water supply (NCC (2001b)):

that future investment in new schemes or extensions to existing schemes be undertaken only after appraisal indicates it is economically viable and ecologically sustainable’

In addition, clause 3(a) (i.) of the COAG framework specifies commitments in regard to full cost recovery pricing being the:

‘.. adoption of pricing regimes based on the principles of consumption- based pricing, full-cost recovery and desirability of the removal of cross subsidies.."

This report will focus on determining whether the Project demonstrates economic viability. This is not to diminish the importance of the ecological impact of the project but rather to not duplicate the analysis of other organisations such as The Tasmanian Conservation Trust on the environmental impacts of the dam.

The Council considers that economic viability should be demonstrated in the project’s ability to recover its direct costs and provide an adequate return to its investors. New schemes should demonstrate the ability recover (NCC (2001a)):

    • Administration, operations and maintenance costs;
    • Cost of capital
    • Externalities (including environmental impact)
    • Taxes or tax equivalent regimes; and
    • Provision for asset consumption

Externalities were defined by the Council to include environmental and resource management costs attributable to and incurred by the water business. The Experts Group (COAG (1995)) has further defined environmental costs as:

a. River Management costs including:
- Costs of implementing resource management initiatives.

- On-going costs associated with resource management and monitoring.

b. The allocation of natural flows to meet environmental requirements.

Broader costs and benefits to society also need to be considered on larger projects, such as dams. Costs include for example, broader environmental impacts and downstream effects, while benefits could include the impact of increased economic activity.

The Council suggests that governments should only consider providing assistance for construction of new water storages ‘… once the stand alone viability of the project has been demonstrated’ (NCC (2001a))

Economic Assessment-Meander Dam

Proponents for the construction of the Meander Dam have commissioned consultants to prepare two documents providing the economic justification for the dam:

  • Meander Dam Feasibility Study-Agricultural & Economic Report March 2002 ( Feasibility Study)
    Davey & Maynard Agricultural Consulting, Deloitte Touche Tohmatsu, and Serve-Ag Pty Ltd
  • Meander Dam Proposal-Draft Economic Evaluation December 2002 (Economic Evaluation)
    Davey & Maynard Agricultural Consulting

These reports are supported by two surveys of approximately 100 farmers interested in receiving additional water intended to determine the potential demand. The first survey was conducted in September 2001. It identified demand for an additional 24,700 ML of water, 11,300 ML by irrigators with Meander River frontage. Prospective users were re-surveyed in February 2002. This survey included consideration of the price to be charged for water. At a price of $55/ML demand for water was 22,000 ML, with 15,500 on the Meander River. Demand was greatly reduced at higher prices.

Information contained in these documents and the supporting surveys were used by WWF Australia (WWF) to assess whether the proposed dam will meet the COAG economic commitments.

Feasibility Study- March 2002
In March 2002 a feasibility study was prepared for the Meander Dam. The analysis provided in the Feasibility Study did not indicate conclusively whether or not the project was financially viable, that is whether it is capable of providing an adequate return to investors. Sensitivity analysis was run for various scenarios, but judgement is not made as to the most-likely situation, nor is the detailed financial analysis provided.

Statements made in the Study are vague and contradictory, but in general indicate that the project is not financially viable:

  • "…there are good prospects for scheme proving to be financially viable" (p.1);
  • "To be financially viable at the anticipated capital cost, Government contribution may need to be provided at no return." (p.1),
  • "At this cost a commercial viewpoint of the project on a stand-alone basis indicates that it requires additional assistance…"(P.1);
  • "The level of capital required for the project of $29.397M provides a low return on investment under a range of demand scenarios" (p.45)

Based on information provided in the study document WWF prepared a most-likely case scenario for the project. Details of the assumptions underlying this scenario are shown in exhibit 1a. The key assumptions underpinning the projects value are the likely volume of water to be demanded by irrigators and the price that can be charged for that water.

Volume assumption:

The estimated likely demand for irrigation water was based on the results of water demand surveys conducted in September 2001 and later in February 2002. The latest survey included price considerations and concluded that demand for additional water was as follows: (p.16)

Meander river frontage 15,500 ML @ $55/ML price

10,600 ML @ $75/ML price

5,225 ML @ $110/ML price

Off-river demand 6,585 ML @ $55/ML price

960 ML @ $75/ML price

530 ML @ $110/ML price

Report considered off-river demand "unlikely to be realised" due to delivery costs of close to $100 ML (p.14). In addition it was estimated that there would be a 25% loss factor, as water was transferred to these secondary streams (P.31).

The effective cost to off-river users would then be:

Water Cost $55 ML

Transfer Loss $14 ML

Delivery $100 ML

$169 ML

At this price there is likely to be negligible demand by off-river users. It is therefore concluded that a reasonable estimate of water demand would be only that of those users with river frontage: 15,500ML/yr at a price of $55.

Consistent with timing assumptions included in the analysis (p.40), it was assumed that volumes would reach a level of 15,500 ML/year by year 7, with 20% of the demand taken up in year 3, 40% in year 4, 60% in year 5, 80% in year 6.

Price Assumption:

The February survey showed the incremental demand water for by Meander irrigators with river access at various price levels. The revenue produced at each price is shown as follows:

Price ML Volume ML Revenue ($000)

$55 15,500 $852.5

$75 10,600 $795.0

$110 5,225 $574.8

$55/ ML was selected as a reasonable price for water given that it produces highest level of revenue. Increases in price above this level will reduce the value of the project. The information can be shown graphically as follows:

Based on the Discounted Cash Flow analysis presented in exhibit 1b, WWF concludes that under the most-likely case the project will return a negative $16M to those entities funding the dam:

Project Net Present Value ($millions)

Irrigation -$16.8

Hydro 0.7

Total -$16.0

Economic Evaluation December 2002
In December 2002, a revised economic analysis of the Meander Dam was prepared by consultants Davey & Maynard. This analysis attempted to incorporate the broader impacts of the dam but also altered some of the fundamental underlying assumptions of the project. A major change was that the forecast demand for water was increased significantly and timing of that demand was moved forward, with no detail provided on water pricing. Details of these assumptions are as follows:

Volume Assumption:

The analysis assumes the initial demand of 15,500 ML/year will be reached over the four year period after completion of the dam. From that point the demand for water is assumed to continue to increase reaching a level of 24,000 ML/year within ten years. The maximum demand level of 15,500 ML/year estimated in the feasibility study was based on the two surveys conducted and consideration of the price to be charged for water. It is difficult to conceive of a rationale that would change this key assumption and indeed the Economic Analysis has provided none. Will the price of water be reduced? Will more land than anticipated be brought into production? Will off-river users elect to pay $169/ML for water? Will irrigators be asked to pay for all water used rather than only the additional demand?

The following illustrates the difference between the two volume assumptions :

Price Assumption:

The Economic Evaluation did not explicitly forecast the price of water. It was assumed that the cost of water to irrigators is $55/Ml. This price has been assumed to apply to the total level of water demanded. However it may not be appropriate to apply this price to volumes in excess of 15,500 ML/year, since the Survey showed this as being the maximum level demanded at that price. A significant reduction in the price would be required to boost demand 55% as forecast. The lower price would reduce the Project’s value.

Based on the information provided in the Economic Evaluation, WWF prepared a Discounted Cash Flow analysis (exhibit 2b) to determine the projects financial viability. Despite the more optimistic assumptions shown in exhibit 2a, the value of the project for those funding the dam remains negative:

Project Net Present Value ($ Million)

Irrigation -$12.3

Hydro 2.1

Total -$ 10.2

If the assumption on the maximum volume demanded is reduced to 15,500ML/yr,the level supported by the survey information, the resulting Net Present Value of the project will decline to negative $13M:

Project Net Present Value ($ Million)

Irrigation -$15.4

Hydro 2.1

Total -$ 13.3

Does the Proposed Meander Dam meet COAG requirements?
It is clear, from the information provided on the project, that it will be unable to meet its direct costs and provide a return to investors. The analysis presented above has indicated in the most-likely case, the project will produce a negative Net Present Value of between $13 and $16 Million. Even if the water demand were assumed to increase to the dam’s maximum capacity, and pricing remained unchanged, a loss of $10 million would be realised in present value terms. There is a significant risk that even these returns are over-stated. Assumptions on the volume of water demanded are very optimistic. It is assumed that the maximum level of water demanded is available and used each year. Given the variability of stream flows, this is unlikely. Reduced volume assumptions would further undermine the value of the project.

The Council has included both externalities (environmental costs) and taxes as direct costs that should be recovered in investment in new infrastructure. These costs have not been included in the analysis and their inclusion will have a further negative impact on the project.

The consultants’ report has identified direct environmental costs due to changed geomorphology, impacts on threatened plants and impacts on threatened animals but mitigation costs have not been estimated or included in the analysis. TCT has identified loss of habitat for the Spotted Tail Quoll (Dasyurus maculatus) and environmental harm to the rare plant species Epacris (Epacris aff. Exserta) as key environmental impacts. Revenue from the Dam is required to cover these specific mitigation costs and broader resource management costs. Inclusion of these costs is likely to significantly reduce the value of the Project.

The council has also indicated the taxes or tax equivalents should be included in project costs. Commercial investor’s gains on the project would clearly be subject to taxation. It can also be argued that the Government’s returns should be subjected to a Tax Equivalent Regime in the interests of Competitive Neutrality.

It is clear that revenue generated by the proposed Meander dam will be insufficient to cover direct costs and provide a return to investors, it is therefore considered not to have meet COAG’s obligation to achieve economic viability as defined in clause 3(d) (iii). In addition, full cost recovery will not be achieved at the proposed price of $55/ML and price increases above this level will reduce demand and total revenue, therefore the project will not meet the obligations in clause 3(d)(i.)

Broader economic considerations
The question arises as to whether the Government should subsidise the dam, despite its not being financially viable, to achieve public benefits. The Economic Evaluation has made an attempt to quantify both benefits to the general public and those benefits accruing directly to irrigators.

The consultants have made a significant effort to quantify the benefits to the community in terms of flood mitigation, water quality and recreation. These have been valued at an NPV of $2.2 million. Unfortunately the costs to the community particularly the environmental impact due to construction of the Dam, increased irrigation, disruption of flows and sedimentation, have not been quantified.

The report also shows that the dam will provide a significant benefit to individual irrigators. However, the analysis excluded any consideration of the price irrigators would be required to pay for water. Use of 24,000 ML a year was assumed, but the survey indicated that a maximum of 15,500 ML would be demanded at a price of $55/ML. At higher prices, the volume of water demanded by irrigators drops precipitously. The assumption that additional water will provide a significant benefit to irrigators is not supported by the willingness or irrigators to Pay for additional water as indicated by the survey.

Based on the information provided, WWF concludes that economic analysis is incomplete, since no costs to the community have been included and benefits to irrigators are not supported by survey data. In addition there are issues on the distribution of costs and benefits, with the majority of benefits accruing to irrigators, while cost are absorbed by the general community. As a consequence, WWF considers that there is no justification for the Government subsidising the construction of the Meander Dam based on it providing public benefits.

Other issues

  • A part of the rationale used to justify the dam is that it provides an economic benefit by providing environmental flows. Actually this is not the case, what the dam does is make additional water available to irrigators who have been required to reduce extractions to provide environmental flows. The dam provides a benefit to the irrigators. Environmental flows would be required in either case.
  • It is not clear what the relationship (if any) is between the level of water extracted for irrigation and that available to drive the hydro plant. It seems that the more water extracted above the dam, the less available to drive the turbine. No relationship is postulated in the analysis.
  • The WWF analysis has relied on the assumptions and data provided by the consultants. However there remain issues which are open to debate, for example: the appropriate cost of capital to apply; inclusion of dam decommissioning costs, as recommended by the World Commission on Dams (WCD (2000)); the validity of the surveys used to determine Willingness to Pay; other options for supply of irrigation water and hydro power; equity and distribution of costs and benefits. Should the dam proceed, the validity of these and other assumptions may need to be explored.

Conclusion
WWF has reviewed the information provided by the consultants engaged by the proponents to provide the economic justification for construction of the Meander Dam. The intention was to determine whether the project would meet the Tasmanian Government’s obligations under COAG’s Water Reform Framework. The report focuses on COAG’s requirement that new rural water supply infrastructures are economically viable and that water is priced to achieve the full recovery of costs.

On the evidence provided, WWF concludes that the project is not economically viable and therefore will not meet COAG requirements specified in clause 3(d) (iii):

  • The Net Present Value of the project was assessed at between a negative $16 million and $13 million. If environmental costs were included this would be a larger loss.
  • There is no justification for the government subsidising construction of the dam based it providing public benefits. Although some public benefits, with a Net Present Value of $2 million, were quantified by the consultants, no costs (environmental, third party) were included.

WWF considers that full costs will not be recovered at the proposed price of $55/ML. There is no scope for increasing the price, since any price above this level has been demonstrated to reduce demand and total project revenue. Therefore the project will not meet COAG obligations defined in clause 3(d)(i.).

References
Council of Australian Governments (COAG) (1995) Report of the Experts Group on Asset Valuation Methods and Cost Recovery Definitions for the Australian Industry 2/95

Davey & Maynard, Deloitte Touche Tohmatsu, Serve-Ag (2002) Meander Dam Feasibility Study-Agricultural and Economic Report Prepared for Department of Primary Industries Water and Environment

Davey & Maynard (2002) Meander Dam Proposal-Draft Economic Evaluation Prepared for Department of Primary Industries Water and Environment

Green G (2003) Meander Dam Proposal to go to Parliament www.media.tas.gov.au

NCC (National Competition Council) (2003) The 2003 National Competition Policy Assessment Framework for Water Reform Ausinfo, Canberra.

NCC (2001a) Background Paper- Rural Water Pricing Ausinfo, Canberra.

NCC (2001b) Background Paper- New Investment in Rural Water Infrastructure Ausinfo, Canberra.

WCD (World Commission on Dams) (2000) Dams and Development: A new framework for Decision Making http:// www.dams.org

Exhibit 1a
Assumptions
Meander Dam Feasibility Study-March 2002
Most Likely Case
($000)

Irrigation Project

Hydro Project

  1. Capital Cost-Dam.
  2. Estimate of construction cost of dam of $23,470 provided by Hydro Tasmania. Cash flows are assumed to occur at the beginning of year 1, with a two-year construction period. (p.39-40).

  3. Annual Operating Cost-Dam
  4. Operating costs estimated by Hydro Tasmania at $115/yr in real terms (p39)

  5. Volume of water supplied
  6. The estimated likely demand for irrigation water was based on the results of water demand surveys conducted in September 2001 and later in February 2002. The latest survey included price considerations and concluded that demand for additional water was as follows: (p.16)

    Meander river frontage 15,500 ML @ $55/ML price

    10,600 ML @ $75/ML price

    5,225 ML @ $110/ML price

    Off-river demand 6,585 ML @ $55/ML price

    960 ML @ $75/ML price

    530 ML @ $110/ML price

    Report considered off-river demand "unlikely to be realised" due to delivery costs of close to $100 ML (p.14). In addition it was estimated that there would be a 25% loss factor, as water was transferred to these secondary streams (P.31).

    The effective cost to off-river users would then be:

    Water Cost $55 ML

    Transfer Loss $14 ML

    Delivery $100 ML

    $169 ML

    At this price there is likely to be minimal demand by off-river users. It is therefore concluded that a reasonable estimate of water demand would be only that of those users with river frontage: 15,500ML/yr at a price of $55.

    Consistent with timing assumptions included in the analysis (p.40), it was assumed that volumes would reach a level of 15,500 ML/year by year 7, with 20% of the demand taken up in year 3, 40% in year 4, 60% in year 5, 80% in year 6.

     

  7. Price
  8. The February survey showed the incremental demand water for by Meander irrigators with river access at various price levels. The revenue produced at each price is shown as follows:

    Price ML Volume ML Revenue ($000)

    $55 15,500 $852.5

    $75 10,600 $795.0

    $110 5,225 $574.8

    $55/ ML was selected as a reasonable price for water given that it produces highest level of revenue.

  9. Required rate of return-Dam

The Study lists nominal rate of return targets suggested for infrastructure projects by the Commonwealth Competitive Neutrality Complaints Office as (p. 46):

Low Risk 8.6%

Medium Risk 10.6%

High Risk 12.6%

The report goes on to state that the project "…may not be adequately regarded as a low cost venture." due to capital requirements, uncertain revenue due to inconclusive water demand and price sensitivity, government regulation and environmental issues. For this reason the "medium risk" capital cost of 10.6% has been applied to the project.

6. Other Assumptions (Per Study)

  • Inflation 2.5% (p.39)
  • Period of analysis 20 years
  • Terminal value-Perpetuity after year 20 (p.40)
  • Taxes-none assumed
  1. Capital Cost-Hydro.
  2. Estimate of construction cost of Mini Hydro of $5,927 provided by Hydro Tasmania. Cash flows are assumed to occur at the beginning of year 1, with a two-year construction period. (p.39-40).

  3. Annual Operating Cost-Dam
  4. Operating costs estimated by Hydro Tasmania at $75/yr in real terms (p39)

  5. Mini Hydro Sales
  6. Sales revenue consists of the sale of electricity and an allowance for renewable energy certificates. Sales of energy produces $ 455/Yr. Renewable energy certificates produce an additional $325/yr. in real terms. The contribution from the energy certificates lapses after year 2020. (p.47)

  7. Other assumptions

All other assumptions are identical to those of the Irrigation project above.

 

Most Likely Case

Financial Analysis

Exhibit 1b

Nominal

Based on: Feasibility Study, Davey & Maynard March 2002

Year

0

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

($000)

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2022

Adj

1.077

1.60

Capital Costs-Dam

-23470

Irrigation Project

Operating Costs

-115

-124

-127

-130

-133

-137

-140

-144

-147

-151

-155

-159

-163

-167

-171

-175

-179

-184

-188

Volume ML/yr

3100

6200

9300

12400

15500

15500

15500

15500

15500

15500

15500

15500

15500

15500

15500

15500

15500

15500

20%

40%

60%

80%

Price ML

55

59

61

62

64

65

67

69

70

72

74

76

78

80

82

84

86

88

90

Revenue

184

376

579

791

1013

1039

1065

1091

1119

1147

1175

1205

1235

1266

1297

1330

1363

1397

Cash Flow-Irrigation

-23470

0

0

60

249

449

658

877

899

921

944

968

992

1017

1042

1068

1095

1122

1150

1179

1209

NPV cash flows

-18,754

Terminal Value

1,989

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

14921

Net Present Value

-16,765

Discount rate

10.6%

Capital Costs-Hydro

-5927

Hydro Project

Electricity Sales

Sales-to 2002

780

840

861

883

905

927

950

974

999

1024

1049

1075

1102

1130

1158

1187

1217

0

0

Sales-post 2002

455

728

746

Operating Costs

-75

-81

-83

-85

-87

-89

-92

-94

-96

-99

-101

-104

-106

-109

-112

-114

-117

-120

-123

759

778

797

817

838

859

880

902

925

948

972

996

1021

1046

1073

1099

608

623

Cash Flow Hydro

-5927

0

0

759

778

797

817

838

859

880

902

925

948

972

996

1021

1046

1073

1099

608

623

NPV cash flows

-362

Terminal Value

1,025

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

7691

Net Present Value

663

Discount Rate

10.6%

Total NPV

-16,102

Exhibit 2a
Assumptions
Meander Dam Draft Economic Evaluation-December 2002
($000)

Real

Financial Analysis

Exhibit 2b

Based on: Draft Economic Evaluation, Davey & Maynard Dec 2002

Year

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

($000)

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

2021

2022

2023

2024

2025

2026

2027

Capital Costs-Dam

-11735

-11735

Irrigation Project

Operating Costs

-100

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

-200

Volume ML/yr

Flow Recovery

4000

4000

4000

4000

4000

4000

4000

4000

4000

4000

Additional Irrigation

3000

6000

9000

11500

13600

15000

16500

18000

19000

20000

7000

10000

13000

15500

17600

19000

20500

22000

23000

24000

24000

24000

24000

24000

24000

24000

24000

24000

24000

24000

24000

24000

24000

Price ML

55

55

55

55

55

55

55

55

55

55

55

55

55

55

55

55

55

55

55

55