BLANK TEMPLATE FOR SIMPLE RESTRUCTURING - World Bank



Document ofThe World BankReport No: RES24293Restructuring PAPERON APROPOSED Project restructuring of Afghanistan: Second Sustainable Development of Natural Resources IF DOCPROPERTY LoanNo <> "" LOAN IF DOCPROPERTY CreditNo <> "" CREDIT {LOAN/CREDIT} {LOAN/CREDIT} \* MERGEFORMAT Grant Number H699-AF May 31, 2011TO THEthe Islamic rebuplic of afghanistanJune 30, 2016Energy and Extractives Global PracticeSouth Asia RegionABBREVIATIONS AND ACRONYMSEIExtractive IndustriesEITIExtractive Industries Transparency InitiativeIAPInternational Advisory PanelMoMPMinistry of Mines and PetroleumNEPANational Environmental Protection AgencySDNRPFirst Sustainable Development of Natural Resources ProjectSDNRP2Second Sustainable Development of Natural Resources ProjectRegional Vice President:Annette DixonCountry Director:Senior Global Practice Director:Robert SaumAnna Bjerde (Acting)Practice Manager/Manager:Paulo de SaTask Team Leader:Michael StanleyIslamic Republic of AfghanistanThe Second Sustainable Development of Natural ResourcesContentsA.SUMMARYPg. 11 - 12B.PROJECT STATUS Pg. 12 - 13C.PROPOSED CHANGESPg. 13 – 18D. ANNEX 1: PROCURMENT PLANPg. 19 - 20DATA SHEETAfghanistanAfghanistan: Sustainable Development of Natural Resources Project II (P118925)SOUTH ASIAEnergy & Extractives.Report No:RES24293.Basic InformationProject ID: P118925Lending Instrument: Technical Assistance LoanRegional Vice President: Annette DixonOriginal EA Category: Partial Assessment (B)Country Director: Robert J. SaumCurrent EA Category: Partial Assessment (B)Senior Global Practice Director: Anna M. BjerdeOriginal Approval Date: 31-May-2011Practice Manager/Manager: Paulo De SaCurrent Closing Date: 30-Jun-2016Team Leader(s): Michael C. Stanley.Borrower:Ministry of MinesResponsible Agency:.Restructuring TypeForm Type: Full Restructuring PaperDecision Authority: CD DecisionRestructuring Level: Level 2.Financing ( as of 06-Jun-2016 )Key DatesProjectLn/Cr/TFStatusApproval DateSigning DateEffectiveness DateOriginal Closing DateRevised Closing DateP118925IDA-H6990Effective31-May-201116-Jul-201121-Sep-201130-Jun-201630-Jun-2016Disbursements (in Millions)ProjectLn/Cr/TFStatusCurrencyOriginalRevisedCancelledDisbursedUndisbursed% DisbursedP118925IDA-H6990EffectiveXDR32.8026.895.9120.726.1777.Policy WaiversDoes the project depart from the CAS/CPF in content or in other significant respects?Yes [ ]No [ X ]Does the project require any policy waiver(s)?Yes [ ]No [ X ].A. Summary of Proposed ChangesBased on the project review and tracking of indicators, the Bank received a request from the Ministry of Finance requesting a extension of the closing date of the Second Sustainable Development of Natural Resources Project (SDNRP II) (P118925) from June 30, 2016 to March 30, 2017, and a partial cancellation of the remaining activities in the amount of US $3.0 million.Under the proposed restructuring, all project activities would close with the exception of continued financing and completion of a select high-priority activities described as follows in the Financing Agreement: (i)Part B (4) - supporting the implementation of the EITI through: (a) drafting, publishing and disseminating independently reconciled EITI reports; (b) training the MSG representatives on implementing the EITI; (ii)Part B (2), (iii) - providing in-depth support for monitoring the Aynak and Hajigak developments;(iii)Part C (1) - supporting the implementation of the archaeological recovery and preservation plan of the Aynak antiquities; and (iv)Part D - support to the Project Monitoring Unit (PMU), particularly in the areas of monitoring and evaluating project activities, complying with fiduciary and safeguards requirements, public information disclosure, and managing public consultation processesThis extension will allow the government MoMP to continue to receive support on several key activities, a number of which are safeguard related, which and could not be adequately completed under the original project timeline.Change in Implementing AgencyYes [ ]No [ X ]Change in Project's Development ObjectivesYes [ ]No [ X ]Change in Results FrameworkYes [ ]No [ X ]Change in Safeguard Policies TriggeredYes [ ]No [ X ]Change of EA categoryYes [ ]No [ X ]Other Changes to SafeguardsYes [ ]No [ X ]Change in Legal CovenantsYes [ ]No [ X ]Change in Loan Closing Date(s)Yes [ X ]No [ ]Cancellations ProposedYes [ X ]No [ ]Change to Financing PlanYes [ X ]No [ ]Change in Disbursement ArrangementsYes [ ]No [ X ]Reallocation between Disbursement CategoriesYes [ X ]No [ ]Change in Disbursement EstimatesYes [ X ]No [ ]Change to Components and CostYes [ X ]No [ ]Change in Institutional ArrangementsYes [ ]No [ X ]Change in Financial ManagementYes [ ]No [ X ]Change in ProcurementYes [ ]No [ X ]Change in Implementation ScheduleYes [ ]No [ X ]Other Change(s)Yes [ ]No [ X ]Appraisal Summary Change in Economic and Financial AnalysisYes [ ]No [ X ]Appraisal Summary Change in Technical AnalysisYes [ ]No [ X ]Appraisal Summary Change in Social AnalysisYes [ ]No [ X ]Appraisal Summary Change in Environmental AnalysisYes [ ]No [ X ]Appraisal Summary Change in Risk AssessmentYes [ ]No [ X ].B. Project StatusFollowing the mid-term review of the project in 2014, there had been a deepening of effort towards enhancing project performance to ensure achievement of the PDO. Overall improvements were as a result of the appointment of a new Minister of Mines (after over a year of several acting ministers) and the appointment of a new Executive Director (acting) for the PMU, which led to an initial period of increase procurement and disbursements. Nonetheless the Ministry has continued to struggle with catching-up on project implementation, following the very protracted period of political and ministerial instability. As recorded latest Implementation Status Report (ISR, December 2015), indicators on Progress towards Achieving the PDO and the Overall Implementation Progress are both rated as Moderately Unsatisfactorily. The overall (average) fiduciary performance rating of the project was rated Moderately Satisfactory..C. Proposed Changes.Development Objectives/ResultsProject Development ObjectivesOriginal PDOto assist the Ministry of Mines (MoM) and the National Environmental Protection Agency (NEPA) in further improving their capacitiesto effectively regulate Afghanistan‘s mineral resource development in a transparent and efficient manner, and foster private sectordevelopment.Change in Project's Development Objectives.FinancingChange in Loan Closing Date(s)Explanation:The proposed restructuring includes an extension of several key activities under the project, from June 30, 2016 to March 30, 2017. These activities include the following :(i) Component B: Regulation and Monitoring of Operations: a) Support to EITI Implementation; and b) Aynak and Hajigak Monitoring;(ii) Component C: Supporting alternative livelihoods through sustainable ASM and Preservation of Aynak Antiquities: a) Aynak Antiquity Safeguarding;(iii) Component D: Project Implementation Support.Ln/Cr/TFStatusOriginal Closing DateCurrent Closing DateProposed Closing DatePrevious Closing Date(s)Proposed Application Deadline DateIDA-H6990Effective30-Jun-201630-Jun-201630-Mar-201730-Jun-201630-Sep-2017CancellationsExplanation:The proposed restructuring only request a extension of several high priority activities, and a partial cancellation of the remaining activities in the amount US $3.0 million. The government wishes to close out/cancel all remaining activities as originally scheduled (on June 30, 2016).Ln/Cr/TFStatusCurrencyCurrent Amount (in currency)Cancelled Amount (in currency)Proposed Amount (in currency)Value Date of CancellationReason for Cancellation:BORROWER'S REQUEST FOR COUNTRY REASONSIDA-H6990-001DisbursingXDR26,893,000.002,155,720.0024,737,280.0028-Jun-2016Change to Financing PlanExplanation:Revisions to the financing plan are as a result of the US $3.0 million cancellation. Proposed restructuring will place project costs at US $40.0 million.Source(s)At ApprovalCurrent (from AUS)ProposedBORR0.000.000.00IDAT52,000,000.0052,000,000.0040,000,000.00Total52,000,000.0052,000,000.0040,000,000.00ReallocationsExplanation:Only the proposed allocation amount has changed. There is no reallocation between disbursement categories being proposed.Ln/Cr/TFCurrencyCat.No.Current Category of ExpenditureAllocationActual DisbursementsPending CommitmentsAllocationDisbursement % (Type Total)CurrentProposedCurrentProposedIDA-H6990-001XDR1GD,WKS,NON-CON SER,CON SER,IOC&TRNG26,893,000.0019,578,383.480.0024,737,280.00100.00100.00Total:26,893,000.0019,578,383.480.0024,737,280.00Disbursement EstimatesChange in Disbursement EstimatesExplanation:The revisions to the disbursement estimates are as a result of : 1) the extension of a number of priority activities beyond the original closing date of the project in the amount of US $3.24 million; and 2) the partial cancellation of the remaining funds in the amount of US $3.0 millionFiscal YearCurrent (USD)Proposed (USD)20110.000.0020122,503,499.552,503,499.5520132,005,576.192,005,576.1920145,205,014.525,205,014.52201517,694,003.0511,448,845.99201614,941,906.699,114,002.702017650,000.004,963,061.05Total43,000,000.0035,240,000.ponentsChange to Components and CostExplanation:The revised Component Costs under the proposed restructuring reflect:1) Cancellation amount of US $3.0 million, and 2) Shifting government priorities, slow start to mining activities, and a lack of absorptive capacity for the remainder of canceled amount.Current Component NameProposed Component NameCurrent Cost (US$M)Proposed Cost (US$M)ActionComponent A. Award of Contracts and Licenses8,300,000.006,300,000.00RevisedComponent B: Regulation and Monitoring of Operations19,100,000.0013,100,000.00RevisedComponent C: Preservation of Aynak Antiquities and Support for Alternative Livelihoodsthrough Sustainable ASM6,600,000.0011,600,000.00RevisedComponent D: Project Implementation Support9,000,000.009,000,000.00No ChangeTotal: 43,000,000.0040,000,000.00SUMMARY1. The Second Sustainable Development of Natural Resources Project (SDNRP II) was designed as a US $52 million (SDR32.8 million) grant to the Islamic Republic of Afghanistan, and became effective in September 2011. In August 2014, the project underwent its first restructuring to cancel US $9 million from the project and several activities (as a result of shifting government priorities and donor overlap). The Project Development Objective (PDO) is to assist the Ministry of Mines and Petroleum (MoMP) and the National Environmental Protection Agency (NEPA) in further improving their capacities to effectively regulate Afghanistan‘s mineral resource development in a transparent and efficient manner, and foster private sector development. The current closing date scheduled for June 30, 2016. 2. On June 28, 2016 the Government of Afghanistan submitted a formal request to the Bank for a partial cancellation in the amount of US $3.0 million and extension of SDNRP2 for a period of nine months. The proposed restructuring would allow of the continued financing and completion of a select high-priority activities currently under implementation, described as follows in the Financing Agreement to the Project: Part B (4) - supporting the implementation of the EITI through: (a) drafting, publishing and disseminating independently reconciled EITI reports; (b) training the MSG representatives on implementing the EITI; Part B (2), (iii) - providing in-depth support for monitoring the Aynak and Hajigak developments;Part C (1) - supporting the implementation of the archeological recovery and preservation plan of the Aynak antiquities; and Part D - support to the Project Monitoring Unit (PMU), particularly in the areas of monitoring and evaluating project activities, complying with fiduciary and safeguards requirements, public information disclosure, and managing public consultation processes. 3. The justification for the extension for the priority activities is as follows: Aynak and Hajigak Monitoring and Aynak Antiquity Safeguarding both serve to address critical and on-going safeguard issues related to the Aynak mine. They aim to protect the communities around the mine by monitoring enforcement of the contract and assist the government with their archeological protection and conservation efforts. The Aynak Supplementary Resettlement Plan (S-RAP) is in its final stage of preparation and both MoMP and the Aynak affected communities rely on Bank support for implementation of this S-RAP. Should these activities close as scheduled, they may pose a reputational risk to the Bank. In addition, while Afghanistan EITI (AEITI) has been identified as a target under the Tokyo Mutual Accountability Framework, the Bank is one of the few donors providing on-going support. Should support be withdrawn at this stage, the county’s candidacy status could be compromised as the AEITI will not meet its commitment of drafting, publishing and disseminating an annual EITI report. Project implementation support (Component D) includes the maintenance of the Project Management Unit, including meeting its fiduciary obligations (procurement and financial management).4. More broadly, a comprehensive approach is needed to ensure continuity of a diversity of technical assistance, up to the date of effectiveness of the newly proposed Afghanistan Extractives for Development (AE4D, P159402) project. A partial SDRNP2 extension would support the above transaction-focused activities while being complementary to, and reinforcing of, the implementation of a Project Preparation Grant supporting design, appraisal and negotiation of AE4D. This comprehensive approach will ensure responsiveness of assistance to an array of emerging needs, many of which may require additional procurement of consulting services, and/or contract amendments or contract extensions. In addition, this extension will permit resolution of outstanding payment and contract management issues from activities ongoing at this time.PROJECT STATUS 5. From September 27 - October 1, 2015 the Bank team undertook an extensive three week mission, to review project performance and report on implementation and outstanding issues. The resulting Aide Memoire of November 2015 provides a summary of the project six months ahead of project close; including meeting with various departments of the Ministry of Mines & Petroleum, the consultancies under SDNRP2, and reviewing core findings and recommendations.6. The review noted that following the mid-term review of the project in 2014, there had been a deepening of effort towards enhancing project performance to ensure achievement of the PDO. Overall improvements were as a result of the appointment of a new Minister of Mines (after over a year of several acting ministers) and the appointment of a new Executive Director (acting) for the PMU, which led to an initial period of increase procurement and disbursements. Nonetheless the Ministry has continued to struggle with catching-up on project implementation, following the very protracted period of political and ministerial instability. As recorded latest Implementation Status Report (ISR, December 2015), indicators on Progress towards Achieving the PDO and the Overall Implementation Progress are both rated as Moderately Unsatisfactorily. The overall (average) fiduciary performance rating of the project was rated Moderately Satisfactory.7. Low disbursements have been recorded throughout the life of SDNRP2, the result of a number of factors including: (i) an inability of the PMU to undertake the reforms necessary to improve procurement execution, (ii) leading to poor procurement planning and protracted procurement processes; (iii) evolving ministerial priorities; change in ministry leadership; and (iv) financial management issues (such as the time necessary to get allocations approved by MoF and the processing of payments). Early in the life of the project low disbursements were also a result of overlap with the first SDNRP1 project. Progress to Date by Component:8. Component 1 Award of Contracts and Licenses: There have been a total of 10 larger mining and hydrocarbon tenders throughout the country including: Aynak, Hajigak, Badakhshan Gold, Zarkashan deposit, Balkhab Copper Deposit & two oil tenders. Transaction-based activities around Hajigak iron ore were halted as a weakening commodity price, delays in passage of the new Mining Law and appointment of a new Minister MoMP. The Minister has not called on the International Advisory Panel (IAP) since January 2014, partly as a result of recent inactivity around the Aynak and Hajigak transactions, and partly following a decision to refresh the ToR’s and re-compete the assignment. The government has requested additional support in the review of the feasibility study for Aynak, which will take place under the Aynak contract monitoring activity. 9. Component 2 Regulation and Monitoring of Operations: An independent external inspection and contract compliance monitoring system is in place, but field security continues to impede field inspection. Capacity building of NEPA on inspectorate service functions and regulatory monitoring (around ESIA’s) is ongoing through the close of the project. This consultancy was mobilized in August 2014 and its main objectives are to strengthen the existing Environmental and Social Impact Assessment (ESIA) procedures. Over the 15 months they have undertaken a functional review of the environmental legal and policy frame work and SESA-EI Recommendations and Implementation Status, and provided a series of recommendations for reforms and a capacity development plan to which they are implementing. Afghanistan EITI has successfully completed its 4th reconciliation report and it is published after approval of the MSG. Furthermore, Members of AEITI Secretariat and MSG participated in the 7th EITI Global Conference in Lima Peru on 24th-25th of February 2016. While the secretariat and the MSG has been able to complete more than 50% of the work plan, procurement process of the Independent Administrator (Reconciler) for the 5th Reconciliation report inclusive of figures of 2014 has already been started.10. Component 3 Preservation of Aynak antiquities and support for alternative livelihoods through sustainable artisanal and small-scale mining (ASM): The Mes Aynak Archeological program is progressing satisfactorily. Following a draw down in 2014 of international staff given security concerns, and ongoing attrition of staff - new local and international archeologists and a new art conservator are currently being procured which will aid in speeding up the pace and accuracy of the recovery process. In May 2016 in Rome, Italy, UNESCO, in partnership with the government of Afghanistan and the World Bank, successfully organized an international conference on the intersection of development and cultural preservation, and to discuss an action plan for cultural preservation in the country. The ASM/Gem Stones program had stalled out under two previous Ministers, largely a result of a difficult political economy in working within the sector and strong linkages to members of parliament and other officials. Momentum, particularly given the ministry's interest in the small scale and gem stone mining, has now been regained. The program has successfully be able to engage women in a variety of capacities, including training them in jewelry making. The ministry requested support from the project to set up a Lapis Lazuli Bourse aimed at reducing opportunities for smuggling the stones. However, this activity is likely to be implemented under the proposed AE4D project.PROPOSED CHANGES 11. The Second Sustainable Development of Natural Resources Project (SDNRP II) was designed as a US $52 million (SDR32.8 million) grant to the Islamic Republic of Afghanistan, and became effective in September 2011. In April 2014, the project underwent its first restructuring to cancel US $9 million from the project and several activities (as a result of shifting government priorities and donor overlap), reducing total net commitments to US $43 million. The current closing date scheduled for June 30, 2016. The proposed restructuring will be the first extension of the project. 12. On June 28, 2016 the Bank received a request from the Ministry of Finance for a restructuring of the project as follows: 1) an extension of the closing date for the Second Afghanistan Sustainable SDNRP2, from June 30, 2016 to March 30, 2017, and 2) partial cancellation of SDNRP2 in the amount of US $3 million.13. Under the proposed restructuring, all project activities would close with the exception of continued financing and completion of a select high-priority activities described as follows: Table 1: Activities to be ExtendedComponent (PAD)Financing AgreementActivity to be ExtendAmount (USD)JustificationComponent B: Regulation and Monitoring of Operations: Part B (4)Support to EITI Implementation: (a) drafting, publishing and disseminating independently reconciled EITI reports; (b) training the MSG representatives on implementing the EITI.574,042.00Afghanistan EITI (AEITI) has been defined as a target under the Tokyo Mutual Accountability Framework; the Bank is one of the few donors providing on-going support. Should support be withdrawn at this stage it’s likely its candidacy could be compromised as the AEITI will not meet its commitment of drafting, publishing and disseminating an annual EITI ponent B: Regulation and Monitoring of OperationsPart B (2), (iii)Aynak and Hajigak Monitoring: review of the feasibility study for Aynak and possible negotiations support500,000.00Aynak mine is potentially the largest single investment in the country with a high-level is visibility. Part of this activity includes monitoring the applications of environmental and social safeguards under the contract. Component C: Supporting alternative livelihoods through sustainable ASM and Preservation of Aynak AntiquitiesPart C (1)Aynak Antiquity Safeguarding1,665,958Aynak Antiquity Safeguarding serve to address critical and on-going safeguard issues related to the Aynak mine. Should this activity close as scheduled, they may pose a significant reputational risk for the BankComponent D: Project Implementation Support.Part Dsupport to the Project Monitoring Unit (PMU), particularly in the areas of monitoring and evaluating project activities, complying with fiduciary and safeguards requirements, public information disclosure, and managing public consultation processes500,000A professional PMU will need to be maintained to ensure that the activities listed above are carried-out and in accordance of Bank fiduciary guidelines.14. Total estimated required budget is US $3.24 million, while the remaining US $3.0 million will be cancelled from the SDNRP2 budget. Please see the activities costing table below for more details on revised project activities costing table. 15. 4. The partial extension will finance works, goods, training, consulting services, non-consulting services and operating costs under Part B (4), Part B (2) (iii), or Part C (1) and Part D of the project. Revised Withdrawal TableCategoryAmount of the Grant Allocated (expressed in SDR)Percentage of Expenditures to be Financed(inclusive of Taxes)(1)? Goods, works, non-consulting services, consultants’ services, Incremental Operating Costs and Training for the Project22,407,280100% of expenditures incurred before June 30, 2016(2) Goods, works, non-consulting services, consulting services, Incremental Operating costs and Training under Part B (2) (iii), Part B (4) (i)&(ii), Part C(i) and Part D of the project2,330,000100% of expenditures after June 30, 2016 until March 30, 2017Amount cancelled as of August 31, 20145,907,000Amount of cancellation as of June 28, 20162,155,720Total32,800,00016. The above activities will be completed before the new project closing date and no additional extension will be required in the future. During this period of extension from June 30, 2016 to March 30, 2017, there will be parallel preparation of the AE4D project and the will close as soon as AE4D becomes effective.TABLE 2: REVISED COSTING TABLE BY ACTIVITY1st Restructuring (2014)2nd Restructuring (2016)Item Original Indicative Project Costs (million USD) Revised Indicative Project Costs (million USD) -1 Difference (million USD)restructur-1 Revised Indicative Project Costs (million USD)- 2 Difference (million USD)restructur-2Component A: Award of Contracts and Licenses 12.40 8.30 (4.10) 6.30 (2.00)Development of Sector and Sub-Sector Policy Frameworks, including transport corridor assessment 3.60 0.30 (3.30) 0.30 - Tendering processes of mineral deposits including Hajigak 2.80 2.00 (0.80) - (2.00)Advancing Geoscientific Knowledge and Developing a Modern Geo-database 6.00 6.00 0.00 6.00 - Component B: Regulation and Monitoring of Operations 22.00 19.10 (2.90) 13.10 (6.00)Modernization of Cadastre 1.20 1.00 (0.20) 1.00 - Implementation of a Dynamic Inspection & Contract Compliance Regime 6.00 6.00 0.00 0.70 (5.30)NEPA Capacity building 2.00 3.00 1.00 2.20 (0.80)Aynak and Hajigak Monitoring 7.40 2.80 (4.60) 1.90 (0.90)Ministry of Mines Mining Institute 0.10 - (0.10) - Improving the Business Environment and Reform of State Minerals Enterprises 4.90 5.80 0.90 5.80 - Support to EITI implementation 0.20 0.50 0.30 1.50 1.00 Policy Frameworks for Mineral Revenues 0.20 - (0.20) - - Component C: Supporting alternative livelihoods through sustainable ASM and Preservation of Aynak Antiquities 7.60 6.60 (1.00) 11.60 5.00 Aynak Antiquity Safeguarding 5.00 4.00 (1.00) 8.70 4.70 Artisanal and Small-scale Mining Directorate 0.40 0.40 0.00 2.90 2.50 Downstream Development for Gemstone Sector and support for women gemstone cutters and jewelry producers 1.20 1.20 0.00 - (1.20)Support for ASM Communities and Mining Cooperatives through Technical Training 1.00 1.00 0.00 - (1.00)Component D: Project Implementation Support 10.00 9.00 (1.00) 9.00 - Total 52.00 43.00 (9.00) 40.00 (3.00)Annex 1: Revised Procurement Plan for Extended ActivitiesDraft Procurement Plan???Ref.DescriptionEstimated Cost (US$)CommentsAConsultancy Services (Firms)??1Building Archival Repository & Web-Based Database for MoMP 250,000.00 ?? Sub Total 250,000.00 ?BPMU Staff??1Project Director, Fudicary, Admin & Technical National and International staff 715,000.00 Most of the staff have already been recruited under SDNRP-II Project? Sub Total 715,000.00 ?COffice running cost/ Incremental Operation Cost ??Ref.DescriptionEstimated Cost (US$)?1Incremental Operating Cost (Fuel & Vehicle maintenance, Internet, Furniture, Office maintenance etc 105,000.00 ?? Sub Total 105,000.00 ?????DProcurement of Works??1Construction of Surrounding wall for Mes Aynak Museum 150,000.00 ?? Sub Total 150,000.00 ?????ETraining/Workshops??1International travel for MoMP (Meetings, workshop, seminars and conferences) 80,000.00 ?? Sub Total 80,000.00 ?????FConsulting services/ support to Mes Aynak and AEITI ??1Support to Afghanistan Extractive Industry Transparency Initiative AEITI secretariat 500,000.00 ?2Support to Mes Aynak Archeological Site 1,200,000.00 ?? Sub Total 1,700,000.00 ??????Total (A+B+C+D+E+F) 3,000,000.00 ? ................
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