Great point.

So for each 4 pawn cluster, 1 pawn takes another pawn, and the net result is +1 bit once the captor promotes. The remaining 2 pawns in the cluster each need 2 extra bits when promoted => 2 x 2 = 4 bits. So 5 bits per 4-pawn cluster, of which there are 4.

So maximum representation would be 162 + (5 * 4) = 182 bits?