- Methods and Projects
- Standards and Classifications
Standardised Methodological Report
Environmental Accounts: Assets Account and Environmental Services
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1Contact
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1.1Contact organisation
National Statistics Institute of Spain
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1.5Contact mail address
Avenida de Manoteras 50-52 - 28050 Madrid
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1.1Contact organisation
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2Metadata update
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2.1Metadata last certified
02/12/2024
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2.2Metadata last posted
21/12/2023
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2.3Metadata last update
02/12/2024
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2.1Metadata last certified
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3Statistical presentation
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3.1Data description
The Environmental Accounts (EA) are a synthesis statistical operation with the general objective of integrating environmental information in the central system of National Accounts, following the methodology of the United Nations' System of Environmental-Economic Accounting (SEEA), which constitutes the conceptual framework of the EA.
They include a group of satellite accounts compiled using accounting formats that are applicable to different sectorial and territorial scopes, with a great amount of physical data. The use of similar concepts, classifications and norms that the National Accounts allow to expand analysis, without overloading the central system.
The result is an indispensable tool for analysing the interrelations between the environment and the economic in general, and in particular, for evaluating sustainable development through the design and construction of the Sustainable Development Indicator Systems, and for monitoring the actions of environmental policies at national and international levels.
The Environmental Goods and Services Sector (EGSS) accounts report on an economic sector that generates goods and services produced for environmental protection or the management of natural resources.
Products for environmental protection prevent, reduce and mitigate pollution or any other degradation of the environment. Examples are electric vehicles, catalysts and filters to decrease pollutant emissions, wastewater and waste treatment services, noise insulation works or restoration of degraded habitats.
Products for resource management safeguard the stock of natural resources against depletion. Examples are renewable energy production, energy-efficient and passive buildings, seawater desalinization or rainwater recovery, and materials recovery.
EGSS accounts provide data on output and export of environmental goods and services and on the value added of and employment in the environmental goods and services sector.
EGSS data are compiled following the statistical concepts and definitions set out in the UN System of Environmental-Economic Accounting 2012 – Central Framework.
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3.2Classification system
- Clasificaciones utilizadas
The classifications used are consistent with the European System of Accounts (ESA). Data are reported cross-classified by:
- the type of environmental protection or resource management activity (environmental domain);
- economic activity.
Environmental protection activities are classified by environmental domain as set out in the Classification of Environmental Protection Activities - CEPA. Resource management activities are classified as set out in the Classification of Resource Management Activities - CReMA. Economic activity is classified according to the Statistical Classification of Economic Activities in the European Community, Rev. 2 (2008).
See the revised CEPA and CReMA explanatory notes for detail:
- Classification of Environmental Protection Activities (http://ec.europa.eu/eurostat/ramon/nomenclatures/index.cfm?TargetUrl=LST_NOM_DTL&StrNom=CEPA_2000&StrLanguageCode=ES&IntPcKey=&StrLayoutCode=HIERARCHIC&IntCurrentPage=1) and the
- Classification of Resource Management Activities, which has not been established internationally, but is used by Eurostat and required for the estimation of the EGSS.
- Clasificaciones utilizadas
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3.3Sector coverage
EGSS comprises a sector of the economy that produces goods and services aimed at environmental protection and resource management (see SEEA CF 2012 chapter 4). Environmental goods and services either reduce environmental pressures or help maintaining the stock of natural resources or they are designed to be cleaner and more resource efficient than conventional products. Environmental goods and services can be produced by corporations, households, governments and non-profit institutions. The list of environmental activities and products has been set out in the Commission Implementing Regulation (EU) 2015/2174 ('the indicative compendium of environmental goods and services').
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3.4Statistical concepts and definitions
- Employment
Is measured in full-time equivalent jobs engaged in the production of output of environmental goods and services. Full-time equivalent is defined as total hours worked divided by the average annual working hours in a full-time job.
- Environmental goods and services
These are those goods and services aimed at measuring, preventing, limiting, minimising or correcting environmental damage caused to water, air and the soil, as well as problems related to waste, noise and ecosystems (environmental protection), and exhaustion of resources (management of natural resources)
- Environmental protection
This comprises all activities that mainly aim to prevent, reduce or eliminate pollution or any other degradation of the environment. This excludes all activities that, having a beneficial effect on the environment, respond mainly to the technical, hygienic or safety needs of the company.
- Environmental protection activities
Activities including within environmental protection are as follows:
Air and climate protection, waste water management, waste management, soil groundwater and surface waters protection and decontamination, noise and vibration reduction, protection against radiation (excluding outside safety), research and development related to the environment, other environmental protection activities such as training, education, administrative tasks, etc.
In order to see the different activities in more detail, please refer to the Classification of Environment Protection Activities (CAPA), a a European Union framework classification for defining what environmental protection is, and what it isn't. - Exports
Consist of sales, barter, gifts, or grants, of environmental goods and services from residents to non-residents.
- Gross Value Added
Represents the contribution made by the production of environmental goods and services to GDP. It is the difference between the value of the output and intermediate consumption.
- Output
Consists of products that become available for use outside of the producer unit, any goods and services produced for own final use and goods that remain in the inventories at the end of the period in which they are produced. Apart from market output, output for own final use and non-market output, EGSS statistics also include ancillary output, comprising output intended for use within an enterprise.
- Resource management activities
Resource management covers technologies, goods and services reducing the need for and use of non-renewable resources, and may also result in associated, secondary, environmental benefits. Activities belonging to the resource management category can be split according to the natural resources affected and classified according to the Classification of Resource Management Activities (CReMA). This classification involves management of waters, management of forest resources, management of wild flora and fauna, management of energy resources, management of minerals, research and development related to the environment and other natural resource management activities.
- Employment
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3.5Statistical unit
Council Regulation (EEC) No 696/93 of 15 March 1993 on the statistical units for the observation and analysis of the production system in the Community describes the different statistical units of the production system.
The recommended statistical unit for the collection and compilation of EGSS statistics (excluding general government) is the establishment. For general government, the recommendation is to use institutional units and groupings of units as defined in the European System of Accounts (ESA 2010).
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3.6Statistical population
The statistical population is the national economy as defined in SEEA CF 2012 and the European System of Accounts (ESA 2010). It includes all economic activities undertaken by resident units.
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3.7Reference area
Environmental Accounts cover the entire national territory.
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3.8Time coverage
Environmental Goods and Services Accounts present data from 2014 to 2022 + 2023 early estimate.
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3.9Base period
Environmental Accounts shall be updated periodically so as to incorporate the appropriate methodological and statistical changes, specially, base changes of the economic accounts.
The results correspond to the 2019 Benchmark Revision (ESA 2010), being in line with National Accounts data.
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3.1Data description
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4Unit of measure
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4.1Unit of measure
Output, gross value added, and exports are measured in million units of national currency.
Employment is measured in full time equivalents (i.e., full time equivalent jobs).
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4.1Unit of measure
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5Reference period
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5.1Reference period
The reference period is the calendar year.
Data referred to the period: Anual A: 2023.
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5.1Reference period
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6Institutional mandate
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6.1Legal acts and other agreements
The compilation and dissemination of the data are governed by the Statistical Law No. 12/1989 "Public Statistical Function" of May 9, 1989, and Law No. 4/1990 of June 29 on “National Budget of State for the year 1990" amended by Law No. 13/1996 "Fiscal, administrative and social measures" of December 30, 1996, makes compulsory all statistics included in the National Statistics Plan. The National Statistical Plan 2009-2012 was approved by the Royal Decree 1663/2008. It contains the statistics that must be developed in the four year period by the State General Administration's services or any other entity dependent on it. All statistics included in the National Statistics Plan are statistics for state purposes and are obligatory. The National Statistics Plan 2021-2024, approved by Royal Decree 1110/2020, of 15 December, is the Plan currently implemented. This statistical operation has governmental purposes, and it is included in the National Statistics Plan 2021-2024. (Statistics of the State Administration).
EGSS accounts are compiled and reported in accordance with Regulation (EU) No. 691/2011 on European environmental economic accounts (EEEA).
The EEEA follow internationally agreed concepts and definitions set out in the SEEA Central Framework (2012), the international statistical standard adopted by the UN Statistical Commission. They present data in a way that is compatible with National Accounts (ESA, 2010).
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6.2Data sharing
The exchanges of information needed to elaborate statistics between the INE and the rest of the State statistical offices (Ministerial Departments, independent bodies and administrative bodies depending on the State General Administration), or between these offices and the Autonomic statistical offices, are regulated in the LFEP (Law of the Public Statistic Function). This law also regulates the mechanisms of statistical coordination, and concludes cooperation agreements between the different offices when necessary.
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6.1Legal acts and other agreements
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7Confidentiality
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7.1Confidentiality - policy
The Statistical Law No. 12/1989 specifies that the INE cannot publish, or make otherwise available, individual data or statistics that would enable the identification of data for any individual person or entity. Regulation (EC) No 223/2009 on European statistics stipulates the need to establish common principles and guidelines ensuring the confidentiality of data used for the production of European statistics and the access to those confidential data with due account for technical developments and the requirements of users in a democratic society
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7.2Confidentiality - data treatment
INE provides information on the protection of confidentiality at all stages of the statistical process: INE questionnaires for the operations in the national statistical plan include a legal clause protecting data under statistical confidentiality. Notices prior to data collection announcing a statistical operation notify respondents that data are subject to statistical confidentiality at all stages. For data processing, INE employees have available the INE data protection handbook, which specifies the steps that should be taken at each stage of processing to ensure reporting units' individual data are protected. The microdata files provided to users are anonymised.
INE provides information on the protection of confidentiality at all stages of the statistical process: INE questionnaires for the operations in the national statistical plan include a legal clause protecting data under statistical confidentiality. Notices prior to data collection announcing a statistical operation notify respondents that data are subject to statistical confidentiality at all stages. For data processing, INE employees have available the INE data protection handbook, which specifies the steps that should be taken at each stage of processing to ensure reporting units' individual data are protected. The microdata files provided to users are anonymised.
Environmental Accounts are a statistical operation included in the National Statistical Plan, therefore subject to the Law on Public Statistical Services of May 9 1989, and consequently, their data is protected by Statistical Secrecy, at all stages of compilation.
In the following link https://www.ine.es/dyngs/IOE/en/operacion.htm?id=1259945998307 description and characteristics of this operation may be consulted.
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7.1Confidentiality - policy
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8Release policy
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8.1Release calendar
The advance release calendar that shows the precise release dates for the coming year is disseminated in the last quarter of each year.
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8.2Release calendar access
The calendar is disseminated on the INEs Internet website (Publications Calendar)
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8.3User access
The data are released simultaneously according to the advance release calendar to all interested parties by issuing the press release. At the same time, the data are posted on the INE's Internet website (www.ine.es/en) almost immediately after the press release is issued. Also some predefined tailor-made requests are sent to registered users. Some users could receive partial information under embargo as it is publicly described in the European Statistics Code of Practice
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8.1Release calendar
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9Frequency of dissemination
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9.1Frequency of dissemination
The data is disseminated annually.
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9.1Frequency of dissemination
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10Accessibility and clarity
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10.1News release
The results of the statistical operations are normally disseminated by using press releases that can be accessed via both the corresponding menu and the Press Releases Section in the web
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10.2Publications
Users of the Environmental Accounts may access the data regarding Environmental Goods and Services Accounts through the INE website
Specifically, the following sections appear in the Environmental Goods and Services Accounts:- Press release and main results: this contains a summary of the Results obtained during the reference period.
- Detailed results, presenting the complete set of results of the different account series available.
- Results of the pilot studies carried out, prior to the entry into force of Regulation Nº 538/2014 regarding environmental economic accounts. -
10.3On-line database
INEbase is the system the INE uses to store statistical information on the Internet. It contains all the information the INE produces in electronic formats. The primary organisation of the information follows the theme-based classification of the Inventory of Statistical Operations of the State General Administration . The basic unit of INEbase is the statistical operation, defined as the set of activities that lead to obtaining statistical results on a determined sector or subject based on the individually collected data. Also included in the scope of this definition are synthesis preparation.
Access to tables and results in INEBASE (www.ine.es) / Agriculture and environment/Environmental accounts
Number of queries to data tables AC1=1926
Number of queries to metadata AC2=814
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10.4Micro-data access
A lot of statistical operations disseminate public domain anonymized files, available free of charge for downloading in the INE website Microdata Section
Due to the nature of the Environmental Accounts, microdata is not available.
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10.5Other
The policy regarding custom requests is to analyse whether they comply with the statistical secrecy and significance conditions. Following this analysis, a viability report is prepared and sent to the person who has made the request.
Requests are made through the User Services Area:
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10.6Documentation on methodology
The handbook of Environmental Goods and Service Accounts developed by Eurostat (“Environmental goods and services sector accounts Handbook"), may be consulted in their website through the following link:
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10.7Quality documentation
Fields 10.7 to 17 of this document are the quality report intended for the user of this operation.
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10.1News release
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11Quality management
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11.1Quality assurance
Quality assurance framework for the INE statistics is based on the ESSCoP, the European Statistics Code of Practice made by EUROSTAT. The ESSCoP is made up of 16 principles, gathered in three areas: Institutional Environment, Processes and Products. Each principle is associated with some indicators which make possible to measure it. In order to evaluate quality, EUROSTAT provides different tools: the indicators mentioned above, Self-assessment based on the DESAP model, peer review, user satisfaction surveys and other proceedings for evaluation.
The quality of synthesis statistics, such as environmental accounts, is derived from the multiple sources they use. In all of them, we have tried to obtain as accurate information as possible, minimizing the various types of errors that may affect them. On the other hand, the compilation follows the annex V relative to the EGSS of Regulation 538/2014, as well as the recomendations of the Eurostat manual.
The estimates of the EGSS are made based on the methodology designed by Eurostat, using the principles, rules and classifications of the National Accounts, which ensures the internal consistency of the EGSS and other economic modules, as well as comparability with the aggregates of National Accounts. In addition, given that the EGSS shares many characteristics with the Environmental Protection Expenditure Account (EPEA), common standards have been used to estimate the elements shared by both, thus ensuring coherence between environmental accounts.
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11.2Quality assessment
The Commission (Eurostat) shall assess the quality of the data transmitted and may, within 1 month of receipt of the data, request the Member State in question to submit additional information regarding the data or a revised dataset, as appropriate (Article 7.4 of European Regulation nº 691/2011).
The estimates of EGSS accounts are based on the methodology designed by Eurostat, using the principles, rules and classifications of national accounts, which ensures their internal consistency and with other modules of the environmental accounts, as well as comparability with aggregates of national accounts.
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11.1Quality assurance
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12Relevance
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12.1User needs
The environmental accounts enable observing the pressure that the economy exerts on the environment, and studying the means to reduce it. They show the interactions between the economy, households and environmental factors, and therefore offer a greater degree of information than the national accounts in this field.
As an essential data source regarding the environment, these are basic for decision-making in environmental policy and in the development of impact assessments, on both national and international levels. According to the principles of sustainable development included in the Europe 2020 Strategy, and in other initiatives, as well as the advance toward an economy that is efficient in the use of resources and low in emissions, it is increasingly necessary to develop and implement a data framework structure that systematically includes environmental issues as well as economics issues.
Moreover, as they constitute a synthesis statistical operation in the environmental field, they enable identifying gaps and improvements in the Spanish statistical system.
Worth noting among environmental account users are the following:
- Ministries and other public bodies.
- Regional administrations (Autonomous Communities).
- Researchers and Academic institutions.
- Companies and non-profit institutions (company research services, foundations, associations, etc.), trade unions and employers' organisations.
- Press and specialised media.Likewise, there are foreign institutional users (Eurostat, OECD, United Nations, etc.).
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12.2User satisfaction
The INE has carried out general user satisfaction surveys in 2007, 2010, 2013, 2016 and 2019 and it plans to continue doing so every three years. The purpose of these surveys is to find out what users think about the quality of the information of the INE statistics and the extent to which their needs of information are covered. In addition, additional surveys are carried out in order to acknowledge better other fields such as dissemination of the information, quality of some publications...
On the INE website, in its section Methods and Projects / Quality and Code of Practice / INE quality management / User surveys are available surveys conducted to date.(Click next link)
The user satisfaction surveys conducted to date assess the environmental sector in which the statistical operation is set in, which may provide direction with regard to the opinion users have of it.
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12.3Completeness
The Environmental Goods and Services Accounts meet the information requirements demanded by European Parliament and Council Regulation (EU) Nº 538/2014, of 16 April 2014, amending Regulation (EU) Nº 691/2011, regarding the European economic environmental accounts, and therefore, it may be stated that they are comprehensive.
The rate of available compulsory statistical results is 100% (R1=100%).
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12.1User needs
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13Accuracy and reliability
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13.1Overall accuracy
Environmental accounts are synthesis statistics, therefore they are affected by sampling errors coming from sources from which information is collected, which are analysed in order to see if they remain within reasonable limits. Non-sampling errors may come from both the sources and the information treatment in this operation (lack of coverage, measurement errors). In summary, the direct measurement of accuracy in this case is not considered possible.
The main instrument for analysing the accuracy is the analysis of the revisions (see 17.2). The revisions show the degree of proximity between subsequent estimators of the same value, and it is reasonable to assume that the estimators converge on the true value when they are based on better and more reliable data.
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13.2Sampling error
EGSS accounts are compiled using a range of primary statistical sources, by which sampling errors that affect it come from the sources that the information is collected from, which are analysed in order to see if they remain within reasonable limits.
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13.3Non-sampling error
EGSS accounts are compiled using a range of primary statistical sources, it is a synthesis statistical operation, by which sampling errors that affect it may come from both the sources and the actual information treatment in this operation (lack of coverage, measurement errors).
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13.1Overall accuracy
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14Timeliness and punctuality
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14.1Timeliness
The estimates of the Environmental Goods and Services Accounts are sent to Eurostat, at most 22 months following the end of the reference year, in compliance with EU Regulation Nº 125/2022 of 19 November 2021, amending EU Regulation Nº 691/2011, regarding European economic environmental accounts, regulating the periods for transmitting data.
The indicator of the time elapsed between the end of the reference period and the dissemination in INEbase is TP1=12 months for early estimates. TP2= 48 months.
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14.2Punctuality
The results of the Environmental Accounts are published in a timely manner, according to the INE structural statistics publication calendar.
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14.1Timeliness
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15Coherence and Comparability
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15.1Comparability - geographical
The EU Member States use the same methodology for the compilation of estimates, which allows comparability among Environmental Goods and Services Accounts estimates.
The EGSS account includes the products and activities listed in Regulation (EU) 2024/1769. Eurostat, through the indicative list of environmental products and activities, defines the minimum scope of the concepts collected.
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15.2Comparability - over time
The temporary comparability of the EGSS, corresponding to the periods 2014-2022, plus the advance of 2023 can be guaranteed
The number of comparable elements of the time series is 10 (CC2 = 10).
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15.3Coherence - cross domain
Environmental Accounts are coherent with National Accounts.
National Accounts
The estimates of EGSS accounts are based on the methodology designed by Eurostat, using the principles, valuations, rules and classifications of national accounts, which ensures their internal consistency and with other modules of the environmental accounts, as well as comparability with aggregates of national accounts.
GVA, Employment and Exports are, in part, estimated based on national accounts. Ratios are calculated based on national accounts agregates, such as full time equivalent employment, exports from SUT tables or GVA by economic activities. Furthermore, some NACE activities are almost entirely environmental activites (NACE 37-39). In that case National Accounts data become the starting point for the estimates as coherence with EGSS must be ensured.
Environmental Protection Expenditure Accounts
EPEA data are taken as a reference regarding characteristic output, i.e., wastewater management and waste management. Since EPEA provides data on production we ensure that production in EGSS keeps coherence with EPEA.
Other statistics
Since some data on production and exports is provided by the Structural Business Statistics (SBS) and other satellite accounts such as Economy-Wide Material Flow Accounts (EW-MFA) and Air Emission Accounts (AEA), we ensure that production in EGSS keeps coherence with the rest of the statistics and Environmental Accounts.
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15.4Coherence - internal
The annual results of Environmental Goods and Services Accounts are coherent with each other and with the available annual series.
For each estimation, the most updated data are applied. Coherence is kept, in general, because data sources follow the same valuation principles. If some methodological change appears the corresponding adjustment is carried out to reflect only the real variation and not the part caused by the methodology.
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15.1Comparability - geographical
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16Cost and burden
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16.1Cost and burden
In the 2024 annual Program, the estimate of the necessary budget appropriation to finance this Environmental Accounts operation is 41.50 thousand euros.
There is no response burden for informants, since the information provided by other statistics is used.
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16.1Cost and burden
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17Data revision
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17.1Data revision - policy
The INE of Spain has a policy which regulates the basic aspects of statistical data revision, seeking to ensure process transparency and product quality. This policy is laid out in the document approved by the INE board of directors on 13 March of 2015, which is available on the INE website, in the section "Methods and projects/Quality and Code of Practice/INE’s Quality management/INE’s Revision policy" (link).
This general policy sets the criteria that the different type of revisions should follow: routine revision- it is the case of statistics whose production process includes regular revisions-; more extensive revision- when methodological or basic reference source changes take place-; and exceptional revision- for instance, when an error appears in a published statistic-.
Environmental Accounts data is revised coherently with the data revision scheme of the Annual Spanish National Accounts.
Regulation (EU) Nº 538/2014 establishes that in each annual data transmission, data be provided for years n-2, n-1 and n, with n being the reference year.
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17.2Data revision - practice
The factors that determine the revisions of Environmental Accounts estimates are basically the changes in Annual Spanish National Accounts as well as the changes carried out so as to improve estimation procedures.
The INE of Spain publishes on its website the last year of reference with t+12 months of time difference, which has early estimate nature, and the rest of years have provisional nature. The final data are published three years and 12 months (t+48) after the end of the corresponding reference year.
The practical way to proceed consists of publishing the data, indicating their final, provisional or early nature. Each annual estimate is revised for three consecutive years, from early estimates until it ceases to be considered provisional and acquires the final nature.
The A6-RMAR indicator (relative mean absolute revision) of the Gross Valued Added of the Environmental Goods and Services Account 2014-2022 and advance estimate 2023 is 2.04%.
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17.1Data revision - policy
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18Statistical processing
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18.1Source data
As this is a synthesis statistical operation, the Environmental Accounts integrate and manage a large number of economics and environmental information sources.
In the case of the Environmental Goods and Services Account, the following statistical information is used:
Elaborated by the INE:- Structural Business Statistics: Sections of manufacturing industry; supply of electricity, gas, steam and air conditioning; Water supply, sanitation activities, waste management and decontamination; and Services.
- Annual Industrial Products Survey.
- Survey of Products of the Services Sector.
- National annual accounts of Spain, mainly the Tables of origin and destination, accounts of production and exploitation by branches of activity.
- Survey on expenditure on environmental protection by the industry.
- Environmental Protection Expenditure Account.The main data source for EGSS estimation are surveys, which are conducted by the INE (National Statiscal Institute of Spain) but are not specifically designed for environmental purposes. These surveys are: Industrial Products Survey; Structural Business Statistics: industrial and services sectors; Statistics on Products in the Services Sector. In addition, two surveys which are led by the environmental unit, include a module for EGSS (Statistics on Environmental Protection Activities and Surveys on waste generation) but we are facing limitations related to sample size, subsequently they are not the main data source.
Other data sources are:- Administrative data: COFOG, foreign trade data of the Tax Agency for exports.- Reports published by ministries, for different sectors (for example, energy statistics for generarion of electricity from renewable sources and forests data, by the Ministry for the Ecological Transition and the Demographic Challenge, organic agriculture and acquaculture, by the Ministry of Agriculture, Fishing and Food and construction sector data by the Ministriy of Transport, Mobility and Urban Agenda).- Some business associations help us to identify data of environmental products not available from traditional statistics. For instance, condensation boilers and electric vehicles. -
18.2Frequency of data collection
The data is compiled annually.
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18.3Data collection
The data collection techniques may vary, depending on the type of source, the date that the data is available, etc.
In general, the data is sent to the Environmental Accounts unit by the different units compiling it, though on occasion, the information may be obtained directly from the corresponding database.
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18.4Data validation
The base information, from the different statistics, is subjected to a series of processes: identification of outliers, error filtering, adaptation to the terms of the Environmental Accounts.
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18.5Data compilation
The compilation process may be structured in several stages:
1. Updating of base information: collection of available data.
2. Treatment of base information: this is subjected to a series of treatments, consisting of identifying outliers, filtering errors and adapting to the terms of the Environmental Accounts.
3. Preparation of the general structure file. With the new information available, the work file is completed with the breakdown level required in the European accounts Regulation. For each institutional sector, and for the purpose of obtaining more precision in the estimates, auxiliary files are used to work with the greatest breakdown level possible of the different identifiable components thereof.
4. Process of analysing and revising the estimates. The time series of results are analysed, for each sector and transaction, with the objective of detecting possible inconsistencies.
5. Preparation of the final results files with the different formats required: format for mailing to Eurostat, and files for dissemination in INEbase (Results, Methodology, Press Release). -
18.6Adjustment
No seasonal adjustments are carried out.
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18.1Source data
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19Comment
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19.1Comment
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19.1Comment