AT&T 2010 International Greenhouse Gas Emissions Inventory Methodology and Process Detail Document 04/25/2011 Overview The purpose of this document is to provide an overview of the process and activities AT&T used to develop the company s 2010 greenhouse gas (GHG) emissions inventory. The following document provides specific detail on the scope, standards, methodologies and results of AT&T s 2010 inventory efforts. 1. Protocol: AT&T used the fundamentals of The Greenhouse Gas Protocol, A Corporate Accounting and Reporting Standard, Revised Edition by the World Resources Institute (WRI) and World Business Council for Sustainable Development (WBCSD). In addition, the protocol outlined by the EPA Climate Leaders program, which is founded on WRI principles, was applied to select emission sources to determine emissions. 2. Organizational Boundary: AT&T has chosen to utilize the Operational Control approach to consolidate GHG emissions. This approach includes any asset or facility in which AT&T has an operating interest in the inventory. For instance, we included both owned and leased assets in our real estate portfolio and mobile fleet in our inventory. We believe that omitting estimated emissions from leased assets would result in a materially incomplete measurement. AT&T chose to use this approach because it more accurately reflects all operations. However, because there are no uniform and mandatory standards for data acquisition and reporting at this point, it is important to note that AT&T s emissions data cannot accurately be compared to other entities, as their approach might not be comparable to ours. Consistent with the approach used in reporting its 2009 inventory, AT&T has included international Scope 1 emissions from ground fleet vehicles, Scope 2 emissions from electric power, and Scope 3 emissions from business air travel. 1
3. Emission Sources: The following sources within AT&T s operating interest were included in the 2010 Inventory: Emission Source o Scope 1 (Direct): Natural Gas Propane #2 Fuel Oil (Diesel) Ground Fleet Flight Operations Engines (Stationary Generators) Engines (Portable Generators) Refrigerant o Scope 2 (Indirect): Purchased Electric Power Purchased Steam o Scope 3 (Ancillary Indirect): Business Air Travel Business Rental Car Travel 4. Greenhouse Gases The AT&T 2010 inventory includes CO2-e measures of carbon dioxide (CO 2 ), nitrous oxide (N 2 O) methane (CH 4 ) emissions, and hydrofluorocarbons (HFCs). 5. Emission Factors: Consistent with the calculations for 2009, AT&T has elected to utilize guidance from the EPA Climate Leaders for emissions calculations in preparing the 2010 GHG Inventory. The emission factors for each greenhouse gas (CO 2, CH 4, N 2 O, HFC) were taken from guidance documentation and multiplied by the respective global warming potential (GWP) to derive an emission factor in terms of carbon dioxide equivalents (CO 2 -e). Detailed references are listed in Appendix B. 2
6. AT&T s 2010 Greenhouse Gas Emissions Inventory, by Scope: AT&T's 2010 GHG Emissions Inventory by Scope 0.70% 12.33% 86.97% Scope 1 Scope 2 Scope 3 Scope mtons CO2-e % Total 8,966,682 100.00% Scope 1 1,105,251 12.33% Scope 2 7,798,222 86.97% Scope 3 63,210 0.70% 3
7. AT&T s 2010 Greenhouse Gas Emissions Inventory, by Source: AT&T's 2010 GHG Emissions Inventory by Source Electric Power Natural Gas Propane Number 2 Fuel Oil Steam Engine FlightOps Ground Fleet Portable Generators Refrigerant Business Air Travel Rental Car Source mtons CO2-e % Total (mtons CO2e) Natural Gas Propane #2 Fuel Oil / Diesel Ground Fleet Flight Operations Engines (Stationary Generators) Engines (Portable Generators) Refrigerant Purchased Electric Power Purchased Steam Business Air Travel Business Rental Car Travel 8,966,682.00 115,781 4,282 12,252 690,721 13,072 119,715 6,123 143,303 7,785,957.95 12,264 49,622 13,587 100% 1.29% 0.05% 0.14% 7.70% 0.15% 1.33% 0.07% 1.60% 86.83% 0.14% 0.55% 0.15% 4
8. AT&T s 2010 Greenhouse Gas Emissions Inventory, by Gas: Scope Total CO2 CH4 N2O HFC mt CO2-e mt CO2-e % mt CO2-e mt CH4 % mt CO2-e mt N2O % mt CO2-e mt HFC % 1 1,105,251 942,474 85.27% 878 42 0.08% 18,595 60 1.68% 143,303 110 12.97% 2 7,798,222 7,759,723 99.51% 3,377 161 0.04% 35,122 113 0.45% 0 0 0.00% 3 63,209 62,058 98.18% 466 3 0.74% 686 3 1.08% 0 0 0.00% Source Total Scope CO2 CH4 N2O HFC mt CO2-e mt CO2-e mt CO2 % mt CO2-e mt CH4 % mt CO2-e mt N2O % mt CO2-e mt HFC % Natural Gas 115,781 1 115,668 115,668 99.90% 46 2.18 0.04% 68 0.22 0.06% - - 0.00% Propane 4,282 1 4,266 4,266 99.61% 4 0.20 0.10% 13 0.04 0.29% - - 0.00% Number 2 Fuel Oil 12,252 1 12,211 12,211 99.66% 11 0.50 0.09% 31 0.10 0.25% - - 0.00% Engine 119,715 1 119,309 119,309 99.66% 103 4.89 0.09% 303 0.98 0.25% - - 0.00% FlightOps 13,072 1 12,935 12,935 98.95% 8 0.36 0.06% 130 0.42 0.99% - - 0.00% Ground Fleet 690,721 1 671,985 671,985 97.29% 702 33.42 0.10% 18,035 58.18 2.61% - - 0.00% Portable Generators 6,123 1 6,102 6,102 99.66% 5 0.25 0.09% 16 0.05 0.25% - - 0.00% Refrigerant 143,303 1 - - 0.00% - - 0.00% - - 0.00% 143,303 110 100.00% Electric Power 7,785,957.95 2 7,747,508 7,747,508 99.51% 3,373 160.62 0.04% 35,077 113.15 0.45% - - 0.00% Steam 12,264 2 12,215 12,215 99.60% 4 0.20 0.03% 45 0.15 0.37% - - 0.00% Air Travel 49,622 3 48,908 48,908 98.56% 55 2.61 0.11% 660 2.13 1.33% - - 0.00% Rental Car 13,587 3 13,150 13,150 96.79% 411 19.58 3.03% 26 0.08 0.19% - - 0.00% TOTAL 8,966,682.00 8,764,254.97 8,764,254.97 4,721 224.8168 54,403.0845 175.4938 143,303 110 5
9. Data Acquisition: The majority of AT&T s emission source data is collected via enterprise data systems. For instance, the vast majority of AT&T utility bills are paid by a third-party bill payment service. This results in consolidated data collection and improved data accuracy because of the specialized and focused service of our vendor/partner. In addition, the vast majority of AT&T s mobile fleet fuel purchases and miles driven are logged in a centralized fleet management platform, enabling accurate data collection for calculation of fleet emissions. Additional data systems, such as real estate portfolio systems, flight operations management systems, building and emergency engine inventory systems, and travel management systems were also utilized as needed. However, there were some instances in which data estimations were required. Any estimations or assumptions have been documented in the sections below. As described throughout this document, AT&T has employed methodologies for acquiring data and reporting results that are intended to yield an accurate, detailed and fair representation of AT&T s emissions. It is important to note, however, that in the absence of uniform and mandatory processes for data acquisition and reporting of emissions, comparing the results reported by AT&T and those reported by other entities may not yield an accurate comparison of emissions and operations. AT&T commits to continue to review and refine the data acquisition and reporting methodologies for future reports as appropriate to address further development of industry standards. Source Description and Calculation Methodology A discussion of the emission sources included in AT&T s 2010 inventory is below. Sources are listed in descending order of magnitude and methodology references are available in Appendix B. 1. Electric Power Electric power is used to energize AT&T facilities and equipment. Actual electricity usage information was obtained from utility invoices, when available. However, for some facilities in which AT&T operates, no discrete utility bill was available (e.g. a full-service leased facility in which utilities are a component of rent). In these instances, electricity consumption was estimated based on the square footage and type of space. AT&T evaluated the use of the U.S. Energy Information Administration s Commercial Buildings Energy Consumption Survey (CBECS) intensity factors to estimate usage. However, because of the greater electricity intensity of some of AT&T s technical spaces (e.g. telephone switching and data center space) we felt strongly that the CBECS estimate understated consumption for our technical spaces. So, we chose to develop specific intensity measures for these types of spaces. To develop these AT&T-specific intensities, we performed a comprehensive review of consumption data by facility type and square footage. We are confident that this exercise provides a more accurate representation of the consumption for those facilities at which consumption estimation was required. AT&T utilized EPA Climate Leaders guidance (EPA430-K-03-006 - June 2008) and egrid 2010 v1.0 (issued February 2011) to estimate emissions from electricity consumption. For U.S. based facilities where zip code information was available, we utilized the zip codes corresponding egrid 6
Subregion emission factors for CO 2, N 2 O, and CH 4. If zip code was not known, we utilized state-based emissions factors. In the rare case where state information was not known, we used the standardized national emission factors for the U.S. for each pollutant. For facilities outside of the U.S., AT&T utilized International Energy Agency data as per WRI / WBCSD GHG Protocol guidance (International Energy Agency Data Services. 2009. "CO2 Emissions from Fuel Combustion (2009 Edition)"). A detailed list of the emissions factors for purchased electric power can be found in Appendix C. 2. Ground Fleet AT&T s ground fleet is comprised of an assortment of vehicle types from passenger cars to heavy duty trucks. In the U.S., fuel consumption and mileage information is gathered via an enterprise fleet management system that allows AT&T to track fuel purchases for and miles driven by vehicles in the fleet. Fuel consumption data was used to estimate CO 2 emissions. Mileage and vehicle type data were utilized to calculate CH 4 and N 2 O emissions. A small subset of AT&T s fleet is leased for which mileage data is not readily available. For that subset, the ratio of CO 2 -e emissions to CH 4 and N 2 O emissions from the bulk of the fleet was applied to estimate emissions for all pollutants. For international based fleet vehicles, actual activity data were available and utilized for operations in Austria, Belgium, France, Germany, the Netherlands, and Switzerland. The remainder of AT&T s international fleet was estimated based on average fuel use data from known international fleet operations. AT&T utilized EPA Climate Leaders guidance (EPA430K-08-004 - May 2008) for emission factors based on fuel type (primarily unleaded and diesel). 3. Refrigerants Refrigerants are used in building cooling systems. The most commonly used refrigerant within AT&T s portfolio is R-22, which was not considered a GHG per the WRI GHG Protocol. However, a subset of cooling systems exist that makes use of HFC based refrigerants - namely R- 134a. For our 2009 GHG inventory, building inventory systems were analyzed to identify the total tonnage of HFCs in use and applied a standard loss rate. Due to the relatively small portion (1.6%) of the overall inventory these emissions contribute and the stability of consumption from year to year, the emissions have been treated as de minimis in the 2010 inventory and the 2009 values were carried forward for the 2010 inventory. AT&T utilized EPA Climate Leaders guidance (EPA430K-03-004 - May 2008) for emission factors based on refrigerant GWP and standard equipment loss rate. 7
4. Natural Gas Natural gas is used within the AT&T portfolio for facility and equipment heating needs. Consumption data for natural gas was collected via utility invoices that were processed, verified and paid by a third-party bill payment vendor. Potential natural gas usage at leased assets where bills are not paid by AT&T were not estimated. AT&T utilized EPA Climate Leaders guidance (EPA430-K-08-003 - May 2008) to derive emission factors for natural gas. 5. Engines (Stationary and Portable Generators) Engines and stationary generators are used to generate power on an emergency basis at AT&T facilities. These engines are engaged whenever the electricity grid is unavailable or whenever requested as part of a Demand Response program to support grid operations and prevent grid failure. Additionally, monthly maintenance runs occur to ensure each engine is operating properly. These maintenance runs account for the majority of emissions associated with these assets. AT&T also uses engines that power portable generators to support its operations for portable backup power, to power truck-mounted equipment, and for outside field use, such as pumping out of manholes. At this time, AT&T does not have centralized fuel consumption data for these assets. In order to estimate the fuel usage that would become the basis of our emissions estimate, we used engine runtime data (actual maintenance runtime data where available, and average runtime estimates by state when not available), in conjunction with engine horsepower capacity, to estimate fuel consumption used during maintenance runs. We also incorporated runtime from emergency use and Demand Response into the fuel consumption estimate. To estimate fuel usage based on engine runtime, AT&T utilized the guidance provided in Appendix 2 of the Risk Management Guidance for the Permitting of New Stationary Diesel-Fueled Engines, developed by the California Environmental Protection Agency Air Resources Board. http://www.arb.ca.gov/diesel/documents/rmgfinal.pdf AT&T utilized EPA Climate Leaders guidance (EPA430-K-08-003 - May 2008) to derive emission factors. 6. Business Air Travel Business travel on commercial airline carriers is considered a Scope 3 emissions stream. AT&T s travel system captures the mileage flown by AT&T passengers on commercial airline jets. All business air travel including international flights was included. Flight legs were categorized into short, medium, long hauls and the specific emission factors for CO 2, N 2 O, and CH 4 were applied to each flight leg according to EPA Climate Leaders guidance (EPA430-R-08-006 May 2008) (see below). 8
Table 1. Air Travel Emission Factors 7. Flight Operations AT&T uses corporate jets to transport AT&T passengers for business travel and for network support operations in remote areas such as Alaska. The travel data, including flight leg miles flown and fuel consumption, are managed by a specific flight management system. AT&T utilized EPA Climate Leaders guidance (EPA430-K-08-004 - May 2008), Table B-2 for CO 2 and Table A-6 for N 2 O, and CH 4 to estimate emissions for Jet Fuel. 8. Purchased Steam Steam is primarily used within the AT&T portfolio for facility and equipment heating needs. Consumption data for steam was collected via utility invoices that were processed, verified and paid by a third-party bill payment vendor. AT&T utilized EPA Climate Leaders guidance (EPA430-K-03-006 - June 2008) and the average heat input of saturated steam and standard boiler efficiency to derive emission factors. 9
9. Business Rental Car Travel Business rental car travel via commercial vendors is considered a Scope 3 emissions stream. To estimate this emission source, AT&T engaged its primary rental car vendors to gather mileage driven by car class for AT&T passengers. These primary vendors were estimated to represent 90% of the total; the remaining balance was extrapolated based on available data. AT&T utilized EPA Climate Leaders guidance (EPA430-K-08-004, Table B-1) to derive the CO 2 emission factor. In order to calculate N 2 O and CH 4 emissions, vehicle miles were assigned car or light-duty truck classifications, and the appropriate emission factors were applied based on EPA Climate Leaders guidance in EPA430-R-08-006, Table 2. Table 1. Ground Fleet CO 2 Emission Factor Table 2. Ground Fleet CH 4 & N 2 O Emission Factors 10. No. 2 Fuel Oil (Diesel) No. 2 Fuel Oil (also called stationary Diesel ) is primarily used within the AT&T portfolio for facility and equipment heating needs as a stationary fuel. Diesel is also used in engines and ground fleet, but these sources are documented in other sections of this document. Consumption data for Fuel Oil was collected via utility invoices that were processed, verified and paid by a third-party bill payment vendor. AT&T utilized EPA Climate Leaders guidance (EPA430-K-08-003 - May 2008) to derive emission factors for Fuel Oil. 10
11. Propane Propane is primarily used within the AT&T portfolio for facility and equipment heating needs and for on-site fork trucks. In addition, handheld propane is used in the field for operational needs. The bulk of propane usage information was obtained from utility invoices from AT&T s thirdparty bill payment service provider. In addition, propane consumption used for field operations was estimated based on average consumption per technician, based on a sampling of usage data from several locations across the country. Due to the relatively small portion (0.05%) of the overall inventory these emissions contribute and the stability of consumption from year to year, the emissions have been treated as de minimis in the 2010 inventory and the 2009 values were carried forward for the 2010 inventory. AT&T utilized EPA Climate Leaders guidance (EPA430-K-08-003 - May 2008) to derive emission factors for propane. 11
Appendix A: Emission Factor Summary Scope Source CO2 Units CH4 Units N2O Units 1 Natural Gas 116.977 lbs CO2-e/MMBtu 0.0463 lbs CO2-e/MMBtu 0.0683 lbs CO2-e/MMBtu 1 Propane 12.653 lbs CO2-e/gallon 0.0126 lbs CO2-e/gallon 0.0373 lbs CO2-e/gallon 1 Number 2 Fuel Oil 22.416 lbs CO2-e/gallon 0.0193 lbs CO2-e/gallon 0.0570 lbs CO2-e/gallon 1 Engines (Stationary) 22.416 lbs CO2-e/gallon 0.0193 lbs CO2-e/gallon 0.0570 lbs CO2-e/gallon 1 Portable Generators 22.416 lbs CO2-e/gallon 0.0193 lbs CO2-e/gallon 0.0570 lbs CO2-e/gallon 1 FlightOps 21.098 lbs CO2-e/gallon 0.0125 lbs CO2-e/gallon 0.2119 lbs CO2-e/gallon 1 Ground Fleet Due to multiple fuel types, consult Methodology Discussion for Emission Factor details. 1 Refrigerant Leakage rate of 15% and 134a GWP of 1300. 2 Electric Power See Appendix C for Electric Power Emission Factors 2 Steam 0.2156 lbs CO2-e/lbs steam 0.000073 lbs CO2-e/lbs steam 0.00080 lbs CO2-e/lbs steam 3 Business Air Travel* - lbs CO2-e/unit *.03 g / passenger mile 0.0085 g / passenger mile 3 Business Rental Car Travel** 19.4227 lbs CO2-e/unit - lbs CO2-e/unit - lbs CO2-e/unit *See methodology for CO2 emission factors for Business Air Travel short, medium, and long hauls. **See methodology for N2O and CH4 emission factors for Business Rental Car Travel. 12
Appendix B: Summary of Methodology Sources Source Reporting Protocol Source File File Name Page # Table # Link to Document Table B-2 EPA430K-08-004 Direct Emissions from Mobile CO2; Table http://www.epa.gov/climateleaders/d A-6 N2O & ocuments/resources/mobilesource_gui FlightOps EPA Climate Leaders May 2008 Combustion Sources 27 CH4 dance.pdf GrFleet EPA Climate Leaders EPA430K-08-004 May 2008 Direct Emissions from Mobile Combustion Sources 26 Table B-1 Direct HFC and PFC Emissions from Use of Refrigeration and Refrigerant EPA Climate Leaders EPA430-K-003-004 Air Conditioning Equipment 11 Table 2 Indirect Emissions from EPA430-K-03-006 Purchases/Sales of Electricity and EP EPA Climate Leaders June 2008 Steam 11 - Indirect Emissions from EPA430-K-03-006 Purchases/Sales of Electricity and Steam EPA Climate Leaders June 2008 Steam 12 - Optional Emissions from Business Air EPA430-R-08-006 Commuting, Business Travel, and Travel EPA Climate Leaders May 2008 Product Transport 7 Table 4 http://www.epa.gov/climateleaders/d ocuments/resources/mobilesource_gui dance.pdf http://www.epa.gov/stateply/docume nts/resources/mfgrfg.pdf http://www.epa.gov/stateply/docume nts/resources/indirect_electricity_guid ance.pdf; http://www.epa.gov/stateply/docume nts/resources/indirect_electricity_guid ance.pdf http://www.epa.gov/stateply/docume nts/resources/commute_travel_produc t.pdf Business Rental Car Travel EPA Climate Leaders EPA430-R-08-006 May 2008 Optional Emissions from Commuting, Business Travel, and Product Transport 3 Table 1 http://www.epa.gov/stateply/docume nts/resources/commute_travel_produc t.pdf 13
Source NG LPG Fuel Oil Engine PortGen Reporting Protocol EPA Climate Leaders EPA Climate Leaders EPA Climate Leaders EPA Climate Leaders EPA Climate Leaders Source File EPA430- K-08-003 May 2008 EPA430- K-08-003 May 2008 EPA430- K-08-003 May 2008 EPA430- K-08-003 May 2008 EPA430- K-08-003 May 2008 File Name Direct Emissions from Stationary Combustion Sources 27 Direct Emissions from Stationary Combustion Sources 27 Direct Emissions from Stationary Combustion Sources 27 Direct Emissions from Stationary Combustion Sources 27 Direct Emissions from Stationary Combustion Sources 27 Page # Table # Document Table B- 3; Table A-1 adjusted for fuel type http://www.epa.gov/stateply/documents/resources/stationarycombustionguidance.pdf Table B- 3; Table A-1 adjusted for fuel type http://www.epa.gov/stateply/documents/resources/stationarycombustionguidance.pdf Table B- 3; Table A-1 adjusted for fuel type http://www.epa.gov/stateply/documents/resources/stationarycombustionguidance.pdf Table B- 3; Table A-1 adjusted for fuel type http://www.epa.gov/stateply/documents/resources/stationarycombustionguidance.pdf Table B- 3; Table A-1 adjusted for fuel type http://www.epa.gov/stateply/documents/resources/stationarycombustionguidance.pdf 14
Appendix C: Electric Power Emission Factors USEPA s egrid 2010 v1.0 (w/ 2007 data): http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html 15
WRI/ WBCSD GHG Protocol. International Energy Agency Data Services. 2009. "CO2 Emissions from Fuel Combustion (2009 Edition)". IEA Country g CO2/kWh Albania 32.4402 Algeria 688.1182 Angola 98.2004 Argentina 303.3696 Armenia 138.2909 Australia 920.527 Austria 214.471 Azerbaijan 473.4752 Bahrain 824.8637 Bangladesh 584.3308 Belarus 296.3771 Belgium 260.036 Benin 696.2126 Bolivia 504.9688 Bosnia and Herzegovina 801.958 Botswana 1851.4539 Brazil 81.4376 Brunei Darussalam 821.0049 Bulgaria 447.9618 Cambodia 1004.9344 Cameroon 42.5357 Canada 184.179 Chile 294.2425 China (including Hong Kong) 788.3087 Colombia 149.6172 Congo 102.3289 Democratic Republic of Congo 2.7816 Costa Rica 47.3985 Côte d'ivoire 436.2172 Croatia 318.398 Cuba 1019.4389 Cyprus 758.2802 Czech Republic 526.629 Denmark 341.339 Dominican Republic 623.8551 Ecuador 395.7349 Egypt 469.8084 El Salvador 216.7277 Eritrea 690.342 Estonia 640.1581 Ethiopia 2.914 Finland 241.592 France 84.953 Gabon 346.6605 Georgia 144.9678 Germany 403.629 16
Ghana 275.6985 Gibraltar 730.4305 Greece 724.964 Guatemala 334.4147 Haiti 305.1825 Honduras 413.2526 Hong Kong, China 854.6126 Hungary 343.927 Iceland 0.542 India 944.0385 Indonesia 676.7253 Iran 514.3547 Iraq 700.9096 Ireland 535.333 Israel 773.651 Italy 403.512 Jamaica 829.7551 Japan 418.346 Jordan 601.8739 Kazakhstan 520.0265 Kenya 317.4905 North Korea 533.1955 South Korea 464.337 Kuwait 642.9168 Kyrgyzstan 79.161 Latvia 167.3881 Lebanon 694.6497 Libya 878.8286 Lithuania 139.482 Luxembourg 326.047 Macedonia 618.9059 Malaysia 655.3582 Malta 834.0854 Mexico 541.285 Moldova 475.568 Mongolia 523.31 Morocco 707.9012 Mozambique 1.0178 Myanmar 338.2211 Namibia 75.6469 Nepal 3.7996 Netherlands 394.315 Netherlands Antilles 717.0685 New Zealand 309.1 Nicaragua 549.7637 Nigeria 386.1378 Norway 6.867 Oman 856.1127 Pakistan 412.8082 Panama 228.8439 17
Paraguay 0 Peru 172.3235 Philippines 435.0061 Poland 658.65 Portugal 416.424 Qatar 625.7141 Romania 428.605 Russia 328.5654 Saudi Arabia 755.3734 Senegal 725.8949 Serbia 715.5911 Singapore 536.0586 Slovak Republic 223.412 Slovenia 331.7589 South Africa 868.9996 Spain 349.794 Sri Lanka 313.7244 Sudan 613.9183 Sweden 47.966 Switzerland 25.723 Syria 604.3992 Tajikistan 28.0183 Tanzania 315.5122 Thailand 510.9283 Togo 458.6697 Trinidad and Tobago 724.3096 Tunisia 545.8586 Turkey 438.222 Turkmenistan 795.1304 Ukraine 344.3288 United Arab Emirates 819.9856 United Kingdom 504.733 Uruguay 296.3499 Uzbekistan 446.36 Venezuela 208.4422 Vietnam 396.3138 Yemen 823.0311 Zambia 6.7574 Zimbabwe 572.7689 18