icra special comment_urea nip_jan 2013

ICRA COMMENT ON NEW UREA INVESTMENT POLICY 2012

Analyst Contacts

K. Ravichandran

[email protected]

+91-44-4596 4301

Pranav Awasthi

[email protected]

+91-124-4545 373

Ankit Deora

[email protected]

+91-22-30470082

Website www.icra.in

Clarity on gas price pass-through in New Urea Investment Policy to incentivise capacity additions of 8-10 MMTPA over the next 5 years

New R-LNG projects and anticipated pick up in domestic gas availability over the next 4-5 years should enable gas tie-ups

Credit profile of urea players undertaking expansion projects will be influenced by the funding mix adopted

Summary

The recently announced New Urea Investment Policy benchmarks

realisation of urea for new projects to import parity prices (IPP),

subject to floating floor and ceiling prices, which are, in turn, linked

to gas prices. As per the policy, the floor-cap prices of urea increase

in line with the gas prices till the gas price of US$ 14/mmbtu, beyond

which the units shall be paid only the floor price based on the

delivered gas prices irrespective of the prevailing IPP and the

concept of ceiling price will not be applicable. The pricing structure

leads to an implicit pass-through of gas prices while providing

reasonable returns to the investors.

Production of urea in India has been stagnant since FY2001 due to

lack of an encouraging policy framework. Consequently, India’s

dependence on imports has increased to the extent of 27% in

FY2012 from nil imports in FY2001. This has led to increase in the

subsidy burden on the Government of India (GoI). The policy should

help reduce subsidy outflows as reliance on imports would reduce

and international prices may also correct due to lower demand from

India.

The new policy is in line with the demand of the industry to do away

with the gas price ceiling of US$ 14/mmbtu in the earlier proposed

policy. Further, it provides downside risk protection through a cost-

plus mechanism (minimum implicit RoE of 12%) and upside benefit

through import parity price (IPP)-linked pricing mechanism (with a

maximum implicit RoE of 20%) for new projects.

Given the clarity on gas price pass-through, ICRA expects at least 5-

6 greenfield / brownfield projects to materialise in the near future.

The policy may help creation of incremental capacities to the extent

of 8-10 million metric tonnes per annum (MMTPA) over the next 5

years.

As the plants get commissioned over the next 3-4 years,

improvement in domestic gas availability and improvement in R-LNG

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ICRA Special Comment New Urea Investment Policy 2012

ICRA Rating Services

infrastructure leading to R-LNG tie-ups should enable long-term gas tie-ups for these new projects.

Currently, GoI is paying a significant subsidy (~Rs. 17,435 crore in FY12) for imported urea. While the

GoI may have to provide higher subsidy in a scenario of high gas prices and low IPP, ICRA expects

that the same would be true only during the interim period while these capacities are being created.

Increase in domestic capacities is expected to lead to decline in import dependence of urea, which

should lead to moderation of global urea prices. Further, improvement in gas availability should lead to

reasonable gas prices, thereby leading to lower urea realisations and correspondingly, lower subsidy.

All these factors are expected to lead to decline in subsidy outflow from GoI for urea in the long term.

Decline in subsidy outflow should also lead to lower subsidy receivables for the urea players, which

should lead to an improvement in the working capital cycle of these players and decline in interest

costs for the working capital borrowings, which have been high for the industry has faced in the recent

past.

Incumbents going for brownfield / greenfield projects will need to undertake substantial investments,

which would affect the capital structure of the companies depending on the funding mix adopted.

Overall, the new investment policy is favourable for the domestic urea industry, given the importance of

attaining self-sufficiency in urea for the country. The policy provides a more transparent mechanism for

managing the high gas prices, which are likely to be faced by the domestic industry on account of

structurally high R-LNG prices in case of lack of domestic gas availability.

Impact Analysis

Heavy reliance on imports of urea due to lack of capacity creation

The production of urea in India has been virtually stagnant since FY2001 because of inadequate capacity

creation arising from a not-so-encouraging

investment policy framework. The Government

of India (GoI) had previously introduced an urea

investment policy in September 2008, providing

import parity (IPP)-linked realisation. The policy

led to some marginal investments in the form of

revamp projects, leading to an increase in

capacity by ~2 MMT – a growth of 10% over the

extant capacity of ~20 MMT. However, the policy

failed to encourage any major brownfield or

greenfield expansion projects, as the policy led

to suboptimal returns under a scenario of i) high

gas prices (due to likely reliance on R-LNG) and

ii) prices of imported urea ruling at the lower end

of the price band suggested in the policy.

On the other hand, the sharp rise in the farm gate price differential in FY2012 of urea as compared to

decontrolled phosphatic fertilisers (post nutrient-based subsidy – NBS) and overuse of urea have increased

India’s dependence on urea imports, which stood at 27% in FY2012 (vs 9% in FY2006 and nil imports in

FY2001). Subsidy on urea imports increased from Rs. 1,211 crore in FY2006 to Rs. 17,435 crore in

FY2012.

New Investment Policy links urea realisations to gas prices

In order to incentivise capacity creation in the urea industry, the Cabinet Committee of Economic Affairs

(CCEA) approved the new urea investment policy on December 13, 2012. Under the new policy, the

realisation of urea from new projects would be benchmarked to import parity prices, subject to a floating

floor and ceiling prices, which are, in turn, linked to gas prices. The base price levels (at a gas price of US$

6.5/mmbtu) for brownfield projects at different prevailing urea IPP are in the range of US$ 285-320/MT,

while those for greenfield projects are in the range of US$ 305-335/MT. The floor-cap band increases in

line with the gas prices (US$ 2/MT for every US$ 0.1/mmbtu rise in gas price) to effectively ensure 12%

and 20% post-tax return on equity (RoE) respectively till US$ 14/mmbtu; for gas prices exceeding US$

0%

5%

10%

15%

20%

25%

30%

35%

-

5

10

15

20

25

30

35

FY06 FY07 FY08 FY09 FY10 FY11 FY12

Production (Lakh MT) Imports (Lakh MT)

Imports % (RHS)

Exhibit 1 – Urea Supply-Demand Scenario

(Source: FAI, Industry, ICRA Analysis)



14/mmbtu, only the floor realisation of urea increases by US$ 2/MT. Beyond a gas price of US$ 14/mmbtu,

the domestic realisations of urea at a given gas price remain constant irrespective of the IPP. The floor and

ceiling prices are meant to be calculated on the basis of average gas prices and import parity prices (IPP)

of urea for the previous quarter.

Earlier, a committee, constituted by the Government of India (GoI) to suggest suitable improvements in the

extant policy of 2008, had proposed a policy which was approved by an Empowered Group of Ministers

(EGoM), but was not approved by the Cabinet Committee of Economic Affairs (CCEA). The policy had

implied a pass-through of gas prices only up to US$ 14/mmbtu. The new policy marks a diversion from the

proposed policy and is in line with the request of the industry to increase the cut-off gas prices to a higher

level or to do away with the ceiling of US$ 14/mmbtu. The new policy covers those projects whose

production starts within five years from the date of notification and would remain in force until eight years

from the start of production, after which the units will be governed by the urea policy prevalent at that time.

ICRA expects the policy to incentivise the fertiliser industry to undertake the much-needed investments to

increase domestic production of urea. It is expected that at least 5-6 brownfield and greenfield projects may

materialise over the next 4-5 years, resulting in capacity creation to the extent of 8-10 million metric tonnes

per annum (MMTPA). Given the current shortfall in domestic production and long-term demand growth

outlook of urea, an additional capacity of 10 MMTPA would result in import dependence declining to 6% of

domestic demand by FY2017 (assuming a CAGR of demand of 3%) from 27% in FY2012.

Downside protection provided while ensuring reasonable returns subject to conformance to capital

cost assumptions

The new policy provides downside risk protection through a cost-plus mechanism (minimum implicit RoE of

12%) and upside benefit through import parity-linked pricing mechanism (with a maximum implicit RoE of

20%). In ICRA’s view, the two critical variables required to achieve these aforesaid normative returns are:

1. Availability of gas

2. Ability to conform to the implicit normative capital cost assumptions (Rs. 4,800 crore for greenfield

project and Rs. 4,200 crore for brownfield project for a standard capacity of 1.27 mmtpa) and

energy consumption norm (of 5 GCal/MT of urea).

Availability of gas: The policy has addressed to some extent the critical variable of gas price pass-

through beyond US$ 14/mmbtu, which was a key shortcoming in the previously proposed policy. The

total gas demand from new urea projects is expected to be significant (~15-16 mmscmd for 8 MMT) in

relation to incremental gas availability in the country. Though the government has prioritized the

fertiliser sector in allocating domestic natural gas (which is significantly cheaper compared to imported

R-LNG), dwindling production from a major source in KG Basin and lack of material addition from the

new discoveries implies that the fertiliser companies have to increasingly rely on R-LNG to meet their

requirement. Though the gas pricing may not be viewed with similar concern by the industry as earlier,

there remains a significant uncertainty over the quantum of domestic gas availability as well as tie-ups

for R-LNG.

Nevertheless, as the plants get commissioned over the next 3-4 years, the domestic gas availability is

expected to improve to some extent, thereby offering some respite to the various stakeholders.

Further, international prices may also moderate to some extent with improving supplies from shale gas

reserves in the US and other countries. R-LNG tie-ups should be enabled by expansion of Petronet

LNG Limited (PLL)’s existing R-LNG terminal in Dahej as well as greenfield projects, such as in Kochi,

Kerala (by PLL), Ennore, Tamil Nadu (by IOC) and Mundra, Gujarat (by GSPC-Adani JV) apart from

the proposed R-LNG terminals and Floating Storage Regassification Units (FSRUs) on the east coast.

However, given that long-term tie-ups might need to be made, ICRA expects gas price tie-ups to be

made at somewhat higher rates (in the range of 12-14 USD/mmbtu).



Conformity to normative assumptions1: Theoretically, the policy ensures post-tax RoE within a band

of 12-20%. However, ICRA expects the corresponding project IRR (post tax) to remain in the band of

12.8%-15.6% (for gas prices of US$ 7-20/mmbtu) for brownfield projects, assuming a 2:1 debt equity

mix (Please refer to Annexure-2 for the post-tax project IRR analysis under the new policy). This is

based on the expectation that the implicit normative assumptions on capex and energy consumption

are achieved by the new urea projects.

In comparison to the extant policy, the new investment policy offers better downside protection for

brownfield & greenfield projects

The new investment policy offers better downside protection when compared to the old investment policy of

2008. The new policy is more attractive than the old policy under the following two scenarios: i) high gas

prices (over $12/mmbtu), which are now pass-through or ii) low IPP (Please refer to Annexure-1 for a

comparison of benchmark prices under the two urea policies). Given the high likelihood of the former, ICRA

believes that the ability of the new policy to address downside risk is relatively favourable from the debt

perspective. Nevertheless, under a scenario of low gas prices and high IPP, the new policy loses its

attractiveness as compared to the existing policy. For example, at the current high IPP of ~US$400/MT and

landed gas cost of USD 8-12/mmbtu, the realisation is similar or lower compared to the old policy at low

gas prices. In the case of revamp projects though, the realisations would be lower compared to the extant

policy, given that gas was available at more moderate prices for the earlier revamp projects and the

applicable realisations at these prices would be lower under the new policy. However, at lower IPP and

high gas prices, the realisations would be better compared to the previous policy.

Exhibit 2 – Existing vs. New Investment Policy

Parameter Old Policy -2008 New Policy 2012 ICRA Comment

Brownfield & Greenfield Projects

Urea Prices

– Floor &

Cap

Fixed Floor-Cap of

$250-425/MT

Floating Floor-Cap till gas price of

US$14/mmbtu; floating floor after that.

Base price levels: Brownfield: $285-

310; Greenfield: $305-$335/tonne

(at US$ 6.5/mmbtu)^

The new policy protects

downside risk (high gas price &

low IPP scenario) through

implicit pass through of gas

prices; moderate upside also

exists (to the extent of RoE of

20% till gas prices of US$

14/mmbtu) at high IPP and

moderate-to-high gas prices

compared to the old policy

Linkage to

Gas prices No

For $0.1/mmbtu increase in gas prices,

Floor-Cap increases by $2/MT till gas

price of US$ 14/mmbtu. After that, only

floor increases by $2/MT.

Urea prices

(% of IPP)

90% for brownfield;

95% for greenfield

90% for brownfield;

95% for greenfield No Change

Revamp Projects

Urea Prices

– Floor &

Cap

Fixed Floor-Cap of

US $250-425

Floating Floor-Cap till gas price of US$

14/mmbtu; floating floor after that.

Base price levels: US$ 245-255

(at US$ 7.5/mmbtu)^

The old policy was better due

to prior access to moderate

priced gas, which gets mapped

to a relatively lower realisation

under new policy, although the

new policy is better at high gas

prices and low IPP

Linkage to

Gas prices No

For $0.1/mmbtu increase in gas prices,

Floor-Cap increases by $2.2/MT

Urea Prices

(% of IPP) 85% 85% No Change

^Note: Base urea prices for Brownfield/Greenfield projects and revamp projects are at different gas prices (US$

6.5/mmbtu for the former and US$ 7.5/mmbtu for the latter)

1 The key assumptions of the committee that recommended the new investment policy for project viability are:

Project cost at Rs. 42 billion for a 1.27 mmtpa, urea brownfield plant; energy consumption at 5 Gcal/tonne of

urea; LCV of gas at 8,100 Kcal/m3; Rs/US$ = 50



Units going for revamp over and above the existing revamp may be considered eligible for NIP-

2012; however, option unlikely to be exercised given lower expected realisations

The urea units already availing the provisions of the Investment Policy of 2008 will remain under that policy.

However, in case of any further revamp undertaken by such units, the same will be considered to be

eligible under NIP-2012 in case the additional capacity is more than 10% of the present production.

However, ICRA believes that the option is unlikely to be exercised given that the existing access to

moderate priced gas results in lower realisation under the new policy and as the old policy offers a higher

upside at the current level of urea prices. For instance, under the earlier policy, if the prevailing urea IPP is

US$400/MT and gas price is US$9/mmbtu, the applicable IPP under the old policy would be US$400/MT,

while that under the new policy would be capped at a substantially lower level of US$288/MT.

Longer loan maturity period or ballooning repayment structure would be positive from the debt

perspective

An analysis of the debt service coverage ratio (DSCR) for a brownfield project with normal assumptions2

indicates that cash flow generation for projects under the new policy should be sufficient to manage the

debt repayments in a scenario of gas prices up to US$ 14/mmbtu, However, some cash flow mismatches

may result in the initial years following the commencement of repayments, particularly at higher gas prices

(Please refer to Annexure-2 for the minimum DSCR analysis). In such a scenario, a longer loan maturity

period or a ballooning repayment structure may be positive from the debt-servicing point of view.

Lower subsidy burden to the GoI over the long term

The GoI’s subsidy payouts for the fertiliser sector have increased substantially from the Rs. 19,400 crore

levels seen in FY2006 to Rs. 73,800 crore in FY2012, primarily due to high import prices. On the urea front,

subsidy payouts have increased both for indigenous production as well as imported urea (Please refer to

Exhibit 4). Payouts for imported urea have increased due to higher global urea prices and depreciation of

Indian Rupee against the US Dollar. On the other hand, production from capacity revamp done by various

urea players coming under the investment policy of 2008 earning IPP-linked realisations have led to

increased subsidy payouts on indigenous production (Please refer to Exhibit 3 for the percentages of

subsidy payouts by GoI on imported and indigenous urea and non-urea fertilisers). Further, higher imports

of urea by India pushes global urea prices upwards.

While it may appear prima-facie that the GoI will have to pay higher realisation for the new investments in a

scenario with low IPP and high gas prices (Please refer Annexure-1), the same would be true only in the

interim period over the next 3-5 years while these capacities are being created. By that time, ICRA expects

that domestic gas availability would have improved to some extent to cater to these incremental capacities.

2 Debt:equity ratio of 2:1 times, four years of moratorium – which includes three years of construction period –

and seven years of repayment period with equated repayments for the term debt

0

200

400

600

800

1000

1200

0%

20%

40%

60%

80%

100%

FY07 FY08 FY09 FY10 FY11 FY12

Rs. B

illion

Imported Urea (%) Indigenous Urea (%)

Others (%) Total Fertiliser Subsidy

0

100

200

300

400

500

0

50

100

150

200

250

300

350

400

FY07 FY08 FY09 FY10 FY11 FY12 FY13

(BE)

US

$/M

T

Rs. B

illio

n

Imported Urea - Subsidy Indigenous Urea - Subsidy

Global Average Urea Prices

Exhibit 3 – Fertiliser Subsidy Payouts on Different

Fertiliser Categories


Exhibit 4 – Subsidy Payouts on Urea vs. Average Global

Urea Prices




Further, the incremental capacity creation should lead to decline in import dependence of urea for India,

which could also lead to moderation of global urea prices – thereby leading to lower costs for urea imports

for the balance requirements. All these factors should lead to lower subsidy outflow from the GoI for urea

over the long term.

Given that urea is highly subsidised as compared to other fertilisers where subsidy is fixed, the NPK

nutrient ratio has witnessed a distortion in the recent past with the FAI estimating an N:P:K ratio of 8.1:3.2:1

for Kharif 2012. Going forward, ICRA does not expect a substantial relaxation of price controls given the

political sensitivity of the urea segment. However, given the modest fiscal position of the GoI, the distortion

of nutrient ratio, which may impact yields going forward and likely increase of gas costs going forward, the

GoI may look to increase the retail prices of urea or accelerate the implementation of NBS for urea in the

medium term.

Conclusion & Rating Implications: The new urea investment policy provides a more transparent

mechanism for reimbursement of higher gas prices, which is a credit positive given that high gas prices is a

reality faced by fertiliser manufacturers due to scarcity of domestic natural gas and structurally high prices

of imported R-LNG. Given the importance of attaining self-sufficiency in urea in terms of low cost

availability and the GoI’s fiscal situation, the new investment policy is a step in the right direction for urea

manufacturers. ICRA expects 5-6 urea projects to materialise in the next 4-5 years, provided that the

companies are able to tie up gas on a long-term basis. In ICRA’s view, new urea investments would be

positive over the long term but would evaluate the impact of these investments on their capital structures

once their funding mix is determined, especially considering the high leveraged position of some of the

players. The key rating sensitivities in this regard will be the funding mix adopted and whether the projects

are taken up on the existing balance sheet or through special purpose vehicles (SPVs). If the SPV route is

adopted, guarantees/letter of comfort extended for the SPV debt would also be a rating sensitivity.

Exhibit 5 – Gearing and Coverage Metrics of Players with Urea Expansion Plans (As of March 31, 2012)

Company Name Outstanding

ICRA Rating

Total Gearing

(times)

Total Debt /

OPBDITA (times)

Chambal Fertilisers & Chemicals Ltd. [ICRA]A1+ 2.00 4.01

Gujarat Narmada Valley Fertilizers &

Chemicals Ltd.

[ICRA]AA- (Stable)

[ICRA]A1+ 0.79 3.34

Gujarat State Fertilizers & Chemicals Ltd. - 0.18 0.54

Indian Farmers Fertiliser Cooperative

Ltd. - 2.28 6.92

Indo Gulf Fertilisers (Aditya Birla Nuvo

Ltd.)

[ICRA]AA+ (Stable)

[ICRA]A1+ 1.46 3.71

Krishak Bharati Cooperative Ltd. - 0.45 -173.90

Nagarjuna Fertilizers & Chemicals Ltd. - 0.89 4.34

Rashtriya Chemicals & Fertilizers Ltd. [ICRA]AA- (Stable) 0.57 2.64

Tata Chemicals Ltd. - 0.49 2.20

Zuari Agro Chemicals Ltd. [ICRA]A

&

[ICRA]A1&

3.78 9.69

& - On “Rating Watch With Developing Implications”



Annexure-1: Comparison of Benchmark Prices for Existing and New Investment Policies for Brownfield Projects

Exhibit 6 – Existing vs. New Investment Policy (Brownfield Projects)

Gas Price (US$/mmbtu) 7 8 9 10 11 12 13 14 15 16 17 18 19 20

Prevailing IPP ----------------------------------------------------------------------------------------------Benchmark Realisation----------------------------------------------------------------------------------------------

<--Old Policy--> <--------------------------------------------------------------------------------New Policy*----------------------------------------------------------------------------------->

250 250 295 315 335 355 375 395 415 435 455 475 495 515 535 555

275 275 295 315 335 355 375 395 415 435 455 475 495 515 535 555

300 300 300 315 335 355 375 395 415 435 455 475 495 515 535 555

325 325 320 325 335 355 375 395 415 435 455 475 495 515 535 555

350 350 320 340 350 355 375 395 415 435 455 475 495 515 535 555

375 375 320 340 360 375 375 395 415 435 455 475 495 515 535 555

400 400 320 340 360 380 400 400 415 435 455 475 495 515 535 555

425 425 320 340 360 380 400 420 425 435 455 475 495 515 535 555

450 425 320 340 360 380 400 420 440 450 455 475 495 515 535 555

475 425 320 340 360 380 400 420 440 460 455 475 495 515 535 555

500 425 320 340 360 380 400 420 440 460 455 475 495 515 535 555

550 425 320 340 360 380 400 420 440 460 455 475 495 515 535 555

600 425 320 340 360 380 400 420 440 460 455 475 495 515 535 555

Exhibit 7 – Realisation comparison between Old and New Policy for Brownfield Project at Various Gas Prices and IPP

Realisation Comparison Scenario

New Policy > Old Policy High Gas Price or Moderate IPP Scenario

Old Policy > New Policy High IPP - Moderate Gas Price

Old Policy = New Policy Moderate IPP - Moderate Gas Price



Annexure-2: Estimated Project Metrics for Brownfield Projects

Exhibit 8 – Post-tax Project IRR Analysis at various urea IPP and gas prices

Gas Price

(USD/mmbtu)

Floor

12% RoE

Ceiling

20% RoE

Actual Import Parity Price (US$/MT)

300 325 350 375 400 425 450 475 500 525 550 575 600

7 295 320 13.1% 13.1% 15.1% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 8 315 340 13.1% 13.1% 13.1% 15.4% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 9 335 360 13.1% 13.1% 13.1% 13.3% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6% 15.6%

10 355 380 13.1% 13.1% 13.1% 13.1% 13.6% 15.5% 15.5% 15.5% 15.5% 15.5% 15.5% 15.5% 15.5% 11 375 400 13.0% 13.0% 13.0% 13.0% 13.0% 13.8% 15.5% 15.5% 15.5% 15.5% 15.5% 15.5% 15.5% 12 395 420 13.0% 13.0% 13.0% 13.0% 13.0% 13.0% 14.0% 15.5% 15.5% 15.5% 15.5% 15.5% 15.5% 13 415 440 13.0% 13.0% 13.0% 13.0% 13.0% 13.0% 13.0% 14.3% 15.5% 15.5% 15.5% 15.5% 15.5% 14 435 460 13.0% 13.0% 13.0% 13.0% 13.0% 13.0% 13.0% 13.0% 14.5% 15.4% 15.4% 15.4% 15.4% 15 455 - 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 16 475 - 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 18 515 - 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 12.9% 20 555 - 12.8% 12.8% 12.8% 12.8% 12.8% 12.8% 12.8% 12.8% 12.8% 12.8% 12.8% 12.8% 12.8%

Exhibit 9 – Minimum DSCR Analysis at various urea and gas prices

(Assuming term loan repayment in 7 years after 4 years of moratorium – incl. 3 years of construction period)

Gas Price

(USD/mmbtu)

Floor

12% RoE

Ceiling

20% RoE

Actual Import Parity Price (US$/MT)

300 325 350 375 400 425 450 475 500 525 550 575 600

7 295 320 1.04 1.04 1.18 1.21 1.21 1.21 1.21 1.21 1.21 1.21 1.21 1.21 1.21

8 315 340 1.04 1.04 1.04 1.19 1.21 1.21 1.21 1.21 1.21 1.21 1.21 1.21 1.21

9 335 360 1.03 1.03 1.03 1.05 1.20 1.20 1.20 1.20 1.20 1.20 1.20 1.20 1.20

10 355 380 1.03 1.03 1.03 1.03 1.06 1.20 1.20 1.20 1.20 1.20 1.20 1.20 1.20

11 375 400 1.02 1.02 1.02 1.02 1.02 1.07 1.19 1.19 1.19 1.19 1.19 1.19 1.19

12 395 420 1.02 1.02 1.02 1.02 1.02 1.02 1.09 1.18 1.18 1.18 1.18 1.18 1.18

13 415 440 1.01 1.01 1.01 1.01 1.01 1.01 1.01 1.10 1.18 1.18 1.18 1.18 1.18

14 435 460 1.01 1.01 1.01 1.01 1.01 1.01 1.01 1.01 1.11 1.17 1.17 1.17 1.17

15 455 - 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 16 475 - 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00

18 515 - 0.99 0.99 0.99 0.99 0.99 0.99 0.99 0.99 0.99 0.99 0.99 0.99 0.99

20 555 - 0.98 0.98 0.98 0.98 0.98 0.98 0.98 0.98 0.98 0.98 0.98 0.98 0.98



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icra special comment_urea nip_jan 2013

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