Sustainability - a Win-Win-Win for
NASA’s Mission, the American People, and the
                  Economy




      Olga Dominguez - Associate Administrator
                 NASA Headquarters
           Office of Strategic Infrastructure
Overview

•   NASA’s Sustainability Policy
•   Existing Communities Of Practice (Cop)
•   Sustainability Requires A Systems Approach
•   Principles Used For Developing NASA’s Strategic Sustainability
    Program Plan (SSPP)
•   Communication, Communication, Communication
•   NASA Has Major Challenges When It Comes To Supporting
    Mission
•   NASA Has Been Doing Sustainability For Many Years As Risk
    Management
•   Vision For A Sustainable NASA
•   A Path Forward For Integrating Sustainability Within NASA
NASA’s Sustainability Policy
NASA's sustainability policy is to execute NASA’s mission without
compromising our planet’s resources so that future generations
can meet their needs.
Sustainability also involves taking action now to provide a future
where the environment and living conditions are protected and
enhanced and in that future NASA will have the resources it needs
to perform its Mission.
NASA is committed to the intent of Executive Order 13514.

NASA is integrating sustainability principles and methods into
existing systems, processes and decision-making, influencing both
long-term planning and short-term actions.

Sustainability will gradually become part of NASA culture.
NASA Communities of Practice (CoPs)
                                  Fleet                 Sustainable
        Procurement            Management               Acquisition
                                                                            Materials and
                                                                             Processes

                                                 Natural
                            Master              Resources
                           Planning                               Environmental
                                                                    Assurance

                          Information
     Maintenance                                 Recycling
                          Technology /                                      Regulatory
    and Operations
                          Data Centers                                    Communication

                 Facility Design
                                         Energy                    Water
                       and
                                       Management                Management
                  Construction


CoPs formed and grew up to meet internal and external goals, objectives, requirements.

Many CoPs have been around for many years. Some are relatively new.
NASA Center and Facility Personnel
   Comprise CoP Membership




CoPs are dispersed geographically throughout NASA.
Sustainability Requires a
                       Systems Approach
Sustainability
   Regulatory       Maintenance and       Environmental
                                                              Master Planning
 Communication        Operations            Assurance


    Energy           Facility Design         Water              Materials and
  Management        and Construction       Management            Processes

                       Information                                Recycling
 Supply Chain                                 Fleet
                    Technology / Data                          and Sustainable
 Management                                Management
                         Centers                                 Acquisition

                     Climate Change
Greenhouse Gas
                       Impacts and         Procurement        Natural Resources
 Management
                        Adaptation

 Because of the multi-disciplinary nature, a sustainability initiative/program
          needs the coordinated efforts from many communities.
Responsible NASA                        SSPP Goal
Agency Team or CoP            Organization for Team
                              or CoP                      1   2   3   4   5   6   7   8   9 10
Strategic Sustainability      OSI                         1   2   3   4   5   6   7   8   9 10
Working Group
Greenhouse Gas Management *   EMD                         1   2   3
Fleet Management              Logistics Management        1   2   3
Energy Management             EMD and FED                 1   2   3   4
Design and Construction       FED                         1   2       4
Maintenance and Operations    FED                         1   2       4
Master Planning               TCRPM and EMD                       3   4   5
Natural Resources             EMD                                         5
Climate Change Impacts and    FCRPM and EMD                               5
Adaptation *
Water Management              EMD                                             6
Procurement                   Office of Procurement       1   2   3               7   8   9
Recycling and Sustainable     EMD                                                 7   8   9
Acquisition (RSA)
Supply Chain Management *     Logistics Management            2   3                   8
Center Chief Information      Chief Information Officer                                   9
Officers
Environmental Assurance and   EMD                                                             10
Green System Design
Materials and Processes       EMD                                                             10
 For most SSPP goals, several CoPs are needed to achieve objectives and targets
Principles Used for Developing
                        NASA’s SSPP
Whenever possible…
                 Utilize established teams, working groups, and communities of practice
 NO NEW TEAMS!   familiar with the functional area to get work done

                 Advise existing management, boards, panels, working groups, etc. to
   NO NEW        ensure that sustainability principles are incorporated into decisions for
 MANAGEMENT!     functional areas

                 Revise existing reports and planning documents generated for the different
   NO NEW        functional areas to reflect the larger sustainability objectives
  REPORTING!

 WORK WITHIN     Define and frame NASA's sustainability approach in a way that blends with
 NASA CULTURE!   NASA culture

  ALIGN WITH     Link all sustainability goals, requirements, targets, and activities to the
   STRATEGY!     NASA Strategy

   MINIMIZE      Create opportunities within NASA's existing activities and projects to meet
  ADDITIONAL     existing and emerging sustainability goals, requirements, and targets by
  RESOURCES!     supplementing with additional funding…
Communication, Communication,
                  Communication


• Ongoing meetings
  of key CoP leads
  within the
  Headquarters
  Sustainability
  Working Group


• HQ CoP leads communicate updates to Center personnel through
  existing meetings, video teleconferences, etc.
• CoP members at Centers communicate upward to HQ CoP Leads
• Communication tools - SSPP as wiki
2010 Efforts to Improve Internal
              Collaboration and Integration
  Senior     • Identify Center Sustainability Officers (CSOs) from
Leadership     Center senior leadership
             • NASA’s Senior Sustainability Officer will meet with
               CSOs at agency-level workshop to discuss new role
             • Describe CSO responsibilities in agency policy -
               drafts developed now, finalized in 2011
             • Make Headquarters Sustainability Working Group
               activities transparent in internal social networking
               tools such as NASA Spacebook
             • Enhance communication within Centers and
               between Centers (e.g., post CoP membership to
               internal sites)
             • Develop collaborative tools for inter-Center
               communication
 Center
Personnel
NASA has major challenges when it
             comes to supporting mission
  aging infrastructure
1 increasing energy cost
 2 greenhouse gas management
  3 climate change impacts and adaptation
   4 changing laws and requirements
     5 mandates without added resources
      6 environmental cleanup – Apollo Era
         7 encroachment – neighbors need
                water, energy, safety, resources…
           8
                 material availability and
              9 obsolescence
major challenge            1     aging infrastructure

       Share of NASA facilities assets under 40 years old
100%


80%


60%


40%


20%         As asset ages rise and requirements evolve, we
            must renew assets upon which our missions
            depend
 0%
   1960          1970        1980         1990       2000
increasing energy cost
                 major challenge                     2
In Since FY 1995, NASA’s energy use is down 12% and unit costs are
                              up 73%.

                                         Unit Cost       Consumption



                        15                                                    15
        $/Million Btu




                                                                                   Trillion Btu
                        10                                                    10


                        5                                                     5


                        0                                                     0
                         1995   1997   1999   2001   2003    2005   2007   2009

                   We are buying less energy yet still spending more.
greenhouse gas
major challenge          3   management




       Electricity for
      Buildings is 82%
         of NASA’s
        Scopes 1&2
climate change
              major challenge                     4     impacts and adaptation
Leverage a unique perspective & renowned climate expertise... to quantify real risks…

                                                                      applying a ground-breaking
                                                                      partnering process.




                                                                       Year 2080 from 1971/2000 base




      ...for an Agency mostly near sea level...




                                                                                    with parts already
                                                                                    being impacted..


    15
changing laws and
                                                                    major challenge                                           5              requirements
                                                 90



                                                 80                                                                                                                EO 13514
                                                                                                                                                           EO 13423
                                                                                                                                                        EO 13327          EISA
CUMULATIVE NUMBER OF LAWS AND EXECUTIVE ORDERS




                                                                                                                                                   EO 13221          EO 13302
                                                                                                                                                    EO 13211      EO 13212
                                                 70                                                                                                 EO 13148       EO 13186
                                                                                                                                                  EO 13089       EO 13112
                                                                                                                                                  EO 13101      TEA-21
                                                                                                                                              SDWA             EO 13061
                                                                                                                                                MMPA         EO 13007
                                                 60                                                                                                        EO 12898
                                                                                                                                         SNARTA           ISTEA
                                                                                                                                         CZARA         OPA
                                                                                                                                        NAGPRA        ADA
                                                                                                                                          CAAA
                                                                                                                                      STURRA         CWA
                                                 50                                                                                               EWRA
                                                                                                                                   CBRA             EPCRA
                                                                                                                                                  HSWA
                                                                                                                                FPPA          RRA
                                                                                                                             ANILCA          LAA
                                                                                                                               ARPA        CERCLA
                                                 40                                                                       CWA             CRA
                                                                                                                                        EO 11998
                                                                                                                           CAA          EO 11990
                                                                                                                       RCRA            SWDA
                                                                                                                          FNWA         MSFCMA
                                                                                                                        AHPA           TSCA
                                                 30                                                                                  SDWA
                                                                                                                      MMPA         ESA
                                                                                                                                   CZMA
                                                                                                                     FAHA          CWA
                                                                                                                      CAA        URA
                                                                                                                                NEPA
                                                 20                                                              WSRA
                                                                                                                             FAHA
                                                                                                                            FAHA
                                                                                                                NHPA       FOIA
                                                                                                                           4(f)
                                                                                                               WQA
                                                                                                               HUDA       HBA
                                                 10                                                                        LWCF
                                                                                                                     RSA SWDA
                                                                            MBTA
                                                                                           HSBAA                FAHA                                                             Post Shuttle
                                                             RHAA   AA                                         CAA
                                                                                            FWCA
                                                                                                     FIFRA
                                                                                                                     Apollo               Shuttle                                 Programs
                                                  0
                                                      1890   1900   1910   1920     1930      1940   1950       1960      1970       1980       1990       2000       2010       2020   2030    2040   2050
                                                                                                                          YEAR
                                                             Air           Chemical Management               Endangered Species                     Energy                              Land/Waste
                                                             Multiple      Natural/Cultural Resources        Other (White Points)                   Transportation                      Water
mandates without
                  major challenge         6   added resources

                                                     New Reporting

            EPA                     DOE

                                                State Laws and
                         New Executive           Regulations
                            Orders




• aging infrastructure
• increasing energy           available                • environmental
  cost                                                   cleanup
• greenhouse gas
                            resources for              • encroachment
  management                   mission                 • climate change
environmental
major challenge   7   cleanup Apollo Era
major challenge                               8           encroachment


                                               Regulatory Issues
                                               Air, Toxics, Wastes
                                                                                 Resources:
                        Environmental
                                                                           Energy, water, materials
                           Liability
 Natural Disaster
Damage & Climate                                                                                        Air Quality
   Variability




Cultural & Historic
    Resources                                                                                         Noise, Hazards




       Security
                                                                                                 Demands for
                                                                                                   Airspace
                                                                                   Radio
                                        Threatened &                             Spectrum
                      Workforce          Endangered        Urban Growth
 19                                        Species         Noise & Light
major challenge/                                material availability and
              opportunity                             9       obsolescence
Partial List of Materials and Processes of Concern                    Shuttle elements
• Trichloroethane                                                     where HCFC 141b is
• Precision Cleaning and Cleanliness Verification Processes           still used
  Requiring ODSs (HCFC 225 and HCFC 225g)
                                                                         RSRM
• TPS and Cryoinsulation Containing ODS (HCFC 141b)
• Chromate Primers                                                         External Tank
• Cadmium Plating
• Hexavalent Chromium Conversion Coating
• Paint Strippers Containing Methylene Chloride
• Lead Based Solid Film Lubricants
• Paints Containing Perchloroethylene
                                                                             Orbiter - Main
• High-Level Volatile Organic Compound (VOC) Coatings
                                                                             Propulsion
• Alkaline Cleaners Containing Hexavalent Chromium                           System, Power
• Hazardous Air Pollutant (HAP) Inks                                         Reactant Storage
• Methyl Ethyl Ketone                                                        and Distribution
• Materials and Products Containing Perfluoroalkyl                           System
  Sulfonates
• Materials Containing Brominated Flame Retardants
• Materials Requiring Perfluorooctanoic Acid (PFOA)
A path forward for integrating sustainability
               within NASA
      View external requirements through the lens of
  1   intent and create opportunities

      Infuse sustainable thinking into existing systems
  2   (ops, design, acquisition, suppliers)

      Design greener systems & processes for NASA
  3   programs & projects & institution

      Develop new models, systems and processes that
  4   support and enhance NASA’s Missions

      Push the envelope of business as usual thru the
  5   sustainability lens
      Sustainability steers you to different, creative, and
                        flexible solutions
View external requirements through the lens of
1     intent and create opportunities
EO 13514 required NASA to prepare and submit to CEQ and OMB a
multi-year Strategic Sustainability Performance Plan.
                            • Started formal sustainability planning
                              process within NASA
                            • In 2011, it will streamline and
                              consolidate reporting requirements
                            • Aligned activities, efforts, and projects
                              outlined in SSPP with NASA budget
                              submission
                            • Initiated inclusion of sustainability into
                              other NASA plans, policies, and
                              activities
                            • Move beyond compliance – identifying
                              opportunities that meet intent
                              provides long-term benefits
Infuse sustainable thinking into existing systems
2   (ops, design, acquisition, suppliers)
Design greener systems & processes for NASA
      3                 programs & projects & institution



                                      Kennedy Space Center
                                      0.95 MW PV System




Restricted or Potentially
Restricted Substances




       Source: NASA-MSFC,
                 MAPTIS-II

                                                             Sustainability Base Ames research Center
Develop new models, systems & processes that
 4      support and enhance NASA’s Missions
 Harvard Business Review – September 2009 – Why Sustainability
               is Now the Key Driver of Innovation




New territory to explore
Push the envelope of business as usual thru the
5     sustainability lens

• Use the opportunity side of risk to design using
  Green Engineering, Green Chemistry, Green Energy
  Management…
• Design and Plan to requirements, outcomes and
  goals desired to drive innovation and use of
  sustainable resources
    – Design to Outcomes and Goals not metrics
• Measure success & individual performance using
  sustainable results
Questions?

Dominguez sustainability seminar

  • 1.
    Sustainability - aWin-Win-Win for NASA’s Mission, the American People, and the Economy Olga Dominguez - Associate Administrator NASA Headquarters Office of Strategic Infrastructure
  • 2.
    Overview • NASA’s Sustainability Policy • Existing Communities Of Practice (Cop) • Sustainability Requires A Systems Approach • Principles Used For Developing NASA’s Strategic Sustainability Program Plan (SSPP) • Communication, Communication, Communication • NASA Has Major Challenges When It Comes To Supporting Mission • NASA Has Been Doing Sustainability For Many Years As Risk Management • Vision For A Sustainable NASA • A Path Forward For Integrating Sustainability Within NASA
  • 3.
    NASA’s Sustainability Policy NASA'ssustainability policy is to execute NASA’s mission without compromising our planet’s resources so that future generations can meet their needs. Sustainability also involves taking action now to provide a future where the environment and living conditions are protected and enhanced and in that future NASA will have the resources it needs to perform its Mission. NASA is committed to the intent of Executive Order 13514. NASA is integrating sustainability principles and methods into existing systems, processes and decision-making, influencing both long-term planning and short-term actions. Sustainability will gradually become part of NASA culture.
  • 4.
    NASA Communities ofPractice (CoPs) Fleet Sustainable Procurement Management Acquisition Materials and Processes Natural Master Resources Planning Environmental Assurance Information Maintenance Recycling Technology / Regulatory and Operations Data Centers Communication Facility Design Energy Water and Management Management Construction CoPs formed and grew up to meet internal and external goals, objectives, requirements. Many CoPs have been around for many years. Some are relatively new.
  • 5.
    NASA Center andFacility Personnel Comprise CoP Membership CoPs are dispersed geographically throughout NASA.
  • 6.
    Sustainability Requires a Systems Approach Sustainability Regulatory Maintenance and Environmental Master Planning Communication Operations Assurance Energy Facility Design Water Materials and Management and Construction Management Processes Information Recycling Supply Chain Fleet Technology / Data and Sustainable Management Management Centers Acquisition Climate Change Greenhouse Gas Impacts and Procurement Natural Resources Management Adaptation Because of the multi-disciplinary nature, a sustainability initiative/program needs the coordinated efforts from many communities.
  • 7.
    Responsible NASA SSPP Goal Agency Team or CoP Organization for Team or CoP 1 2 3 4 5 6 7 8 9 10 Strategic Sustainability OSI 1 2 3 4 5 6 7 8 9 10 Working Group Greenhouse Gas Management * EMD 1 2 3 Fleet Management Logistics Management 1 2 3 Energy Management EMD and FED 1 2 3 4 Design and Construction FED 1 2 4 Maintenance and Operations FED 1 2 4 Master Planning TCRPM and EMD 3 4 5 Natural Resources EMD 5 Climate Change Impacts and FCRPM and EMD 5 Adaptation * Water Management EMD 6 Procurement Office of Procurement 1 2 3 7 8 9 Recycling and Sustainable EMD 7 8 9 Acquisition (RSA) Supply Chain Management * Logistics Management 2 3 8 Center Chief Information Chief Information Officer 9 Officers Environmental Assurance and EMD 10 Green System Design Materials and Processes EMD 10 For most SSPP goals, several CoPs are needed to achieve objectives and targets
  • 8.
    Principles Used forDeveloping NASA’s SSPP Whenever possible… Utilize established teams, working groups, and communities of practice NO NEW TEAMS! familiar with the functional area to get work done Advise existing management, boards, panels, working groups, etc. to NO NEW ensure that sustainability principles are incorporated into decisions for MANAGEMENT! functional areas Revise existing reports and planning documents generated for the different NO NEW functional areas to reflect the larger sustainability objectives REPORTING! WORK WITHIN Define and frame NASA's sustainability approach in a way that blends with NASA CULTURE! NASA culture ALIGN WITH Link all sustainability goals, requirements, targets, and activities to the STRATEGY! NASA Strategy MINIMIZE Create opportunities within NASA's existing activities and projects to meet ADDITIONAL existing and emerging sustainability goals, requirements, and targets by RESOURCES! supplementing with additional funding…
  • 9.
    Communication, Communication, Communication • Ongoing meetings of key CoP leads within the Headquarters Sustainability Working Group • HQ CoP leads communicate updates to Center personnel through existing meetings, video teleconferences, etc. • CoP members at Centers communicate upward to HQ CoP Leads • Communication tools - SSPP as wiki
  • 10.
    2010 Efforts toImprove Internal Collaboration and Integration Senior • Identify Center Sustainability Officers (CSOs) from Leadership Center senior leadership • NASA’s Senior Sustainability Officer will meet with CSOs at agency-level workshop to discuss new role • Describe CSO responsibilities in agency policy - drafts developed now, finalized in 2011 • Make Headquarters Sustainability Working Group activities transparent in internal social networking tools such as NASA Spacebook • Enhance communication within Centers and between Centers (e.g., post CoP membership to internal sites) • Develop collaborative tools for inter-Center communication Center Personnel
  • 11.
    NASA has majorchallenges when it comes to supporting mission aging infrastructure 1 increasing energy cost 2 greenhouse gas management 3 climate change impacts and adaptation 4 changing laws and requirements 5 mandates without added resources 6 environmental cleanup – Apollo Era 7 encroachment – neighbors need water, energy, safety, resources… 8 material availability and 9 obsolescence
  • 12.
    major challenge 1 aging infrastructure Share of NASA facilities assets under 40 years old 100% 80% 60% 40% 20% As asset ages rise and requirements evolve, we must renew assets upon which our missions depend 0% 1960 1970 1980 1990 2000
  • 13.
    increasing energy cost major challenge 2 In Since FY 1995, NASA’s energy use is down 12% and unit costs are up 73%. Unit Cost Consumption 15 15 $/Million Btu Trillion Btu 10 10 5 5 0 0 1995 1997 1999 2001 2003 2005 2007 2009 We are buying less energy yet still spending more.
  • 14.
    greenhouse gas major challenge 3 management Electricity for Buildings is 82% of NASA’s Scopes 1&2
  • 15.
    climate change major challenge 4 impacts and adaptation Leverage a unique perspective & renowned climate expertise... to quantify real risks… applying a ground-breaking partnering process. Year 2080 from 1971/2000 base ...for an Agency mostly near sea level... with parts already being impacted.. 15
  • 16.
    changing laws and major challenge 5 requirements 90 80 EO 13514 EO 13423 EO 13327 EISA CUMULATIVE NUMBER OF LAWS AND EXECUTIVE ORDERS EO 13221 EO 13302 EO 13211 EO 13212 70 EO 13148 EO 13186 EO 13089 EO 13112 EO 13101 TEA-21 SDWA EO 13061 MMPA EO 13007 60 EO 12898 SNARTA ISTEA CZARA OPA NAGPRA ADA CAAA STURRA CWA 50 EWRA CBRA EPCRA HSWA FPPA RRA ANILCA LAA ARPA CERCLA 40 CWA CRA EO 11998 CAA EO 11990 RCRA SWDA FNWA MSFCMA AHPA TSCA 30 SDWA MMPA ESA CZMA FAHA CWA CAA URA NEPA 20 WSRA FAHA FAHA NHPA FOIA 4(f) WQA HUDA HBA 10 LWCF RSA SWDA MBTA HSBAA FAHA Post Shuttle RHAA AA CAA FWCA FIFRA Apollo Shuttle Programs 0 1890 1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 2010 2020 2030 2040 2050 YEAR Air Chemical Management Endangered Species Energy Land/Waste Multiple Natural/Cultural Resources Other (White Points) Transportation Water
  • 17.
    mandates without major challenge 6 added resources New Reporting EPA DOE State Laws and New Executive Regulations Orders • aging infrastructure • increasing energy available • environmental cost cleanup • greenhouse gas resources for • encroachment management mission • climate change
  • 18.
    environmental major challenge 7 cleanup Apollo Era
  • 19.
    major challenge 8 encroachment Regulatory Issues Air, Toxics, Wastes Resources: Environmental Energy, water, materials Liability Natural Disaster Damage & Climate Air Quality Variability Cultural & Historic Resources Noise, Hazards Security Demands for Airspace Radio Threatened & Spectrum Workforce Endangered Urban Growth 19 Species Noise & Light
  • 20.
    major challenge/ material availability and opportunity 9 obsolescence Partial List of Materials and Processes of Concern Shuttle elements • Trichloroethane where HCFC 141b is • Precision Cleaning and Cleanliness Verification Processes still used Requiring ODSs (HCFC 225 and HCFC 225g) RSRM • TPS and Cryoinsulation Containing ODS (HCFC 141b) • Chromate Primers External Tank • Cadmium Plating • Hexavalent Chromium Conversion Coating • Paint Strippers Containing Methylene Chloride • Lead Based Solid Film Lubricants • Paints Containing Perchloroethylene Orbiter - Main • High-Level Volatile Organic Compound (VOC) Coatings Propulsion • Alkaline Cleaners Containing Hexavalent Chromium System, Power • Hazardous Air Pollutant (HAP) Inks Reactant Storage • Methyl Ethyl Ketone and Distribution • Materials and Products Containing Perfluoroalkyl System Sulfonates • Materials Containing Brominated Flame Retardants • Materials Requiring Perfluorooctanoic Acid (PFOA)
  • 21.
    A path forwardfor integrating sustainability within NASA View external requirements through the lens of 1 intent and create opportunities Infuse sustainable thinking into existing systems 2 (ops, design, acquisition, suppliers) Design greener systems & processes for NASA 3 programs & projects & institution Develop new models, systems and processes that 4 support and enhance NASA’s Missions Push the envelope of business as usual thru the 5 sustainability lens Sustainability steers you to different, creative, and flexible solutions
  • 22.
    View external requirementsthrough the lens of 1 intent and create opportunities EO 13514 required NASA to prepare and submit to CEQ and OMB a multi-year Strategic Sustainability Performance Plan. • Started formal sustainability planning process within NASA • In 2011, it will streamline and consolidate reporting requirements • Aligned activities, efforts, and projects outlined in SSPP with NASA budget submission • Initiated inclusion of sustainability into other NASA plans, policies, and activities • Move beyond compliance – identifying opportunities that meet intent provides long-term benefits
  • 23.
    Infuse sustainable thinkinginto existing systems 2 (ops, design, acquisition, suppliers)
  • 24.
    Design greener systems& processes for NASA 3 programs & projects & institution Kennedy Space Center 0.95 MW PV System Restricted or Potentially Restricted Substances Source: NASA-MSFC, MAPTIS-II Sustainability Base Ames research Center
  • 25.
    Develop new models,systems & processes that 4 support and enhance NASA’s Missions Harvard Business Review – September 2009 – Why Sustainability is Now the Key Driver of Innovation New territory to explore
  • 26.
    Push the envelopeof business as usual thru the 5 sustainability lens • Use the opportunity side of risk to design using Green Engineering, Green Chemistry, Green Energy Management… • Design and Plan to requirements, outcomes and goals desired to drive innovation and use of sustainable resources – Design to Outcomes and Goals not metrics • Measure success & individual performance using sustainable results
  • 27.