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Home My WebLink AboutMCUP 13-06; VERIZON WIRELESS CALAVERA HILLS - 1ST EXTENSION; RADIO FREQUENCY EXPOSURE; 2022-06-29f:)Pramira Radio Frequency Exposure RF Safety and NIER Analysis Report 06/29/2022 Site: CAL VERA HILLS CARLSBAD, CA Prepared for: Verizon JUL 11 2022 CIT I (j,-~/\ :..,JciAD :-'~.''.~' .. ' 0'"'1\ "'• Table of Contents I Certification ................................................................................................................ 3 2 Executive Summary .................................................................................................... 4 2.1 Conclusion and Recommendations ...................................................................... 5 3 Introduction ................................................................................................................. 6 3.1 Site Description: ................................................................................................... 6 3.2 Site Configuration Being Modeled ...................................................................... 7 4 Predictive Analysis Details ......................................................................................... 8 4.1 Analysis Locations: .............................................................................................. 8 4.2 Antenna Inventory ................................................................................................ 9 4.3 RF Emissions Diagram(s) -All Transmitters ..................................................... I 0 4.4 RF Emissions Diagram(s) -Verizon Transmitters Only .................................... 11 5 Signage/ Mitigation ................................................................................................... 12 5 .1 S ignage/ Barrier Detai 1... .................................................................................... 12 5.2 Signage/ Barrier Diagram ................................................................................... 13 6 Conclusions and Recommendations ......................................................................... 14 7 Appendix A: FCC Compliance and RF Safety Policies ........................................... 15 8 Appendix B: Overview of RoofMaster® Functions and Assumptions .................... 17 9 References ................................................................................................................. 20 10 Limited Warranty ...................................................................................................... 21 Page 2 of21 1 Certification This report, prepared by Pramira, lnc. for Verizon, is intended to document compliance and evaluate power density levels as outlined in the report. The computations, analysis, and resulting report and conclusions were based on applicable FCC guidelines and regulations for maximum permissible exposure to humans consistent with FCC OET Bulletin 65, Edition 97-0 I. Additionally, Pramira, Inc. certifies that the assumptions are valid and that the data used within Pramira control are accurate, including information collected as part of Pramira field surveys. Pramira, Inc. does not however certify the accuracy or correctness of any data provided to Pramira, Inc. for this analysis and report by Verizon or other third parties working on behalf of Verizon. I certify that the attached RF exposure analysis and report is correct to the best of my knowledge, and all calculations, assumptions and conclusions are based on generally acceptable engineering practices: No. E18344 xp. 3/31/202 SIGNED, 30 JUN 2022 Tim Alexander, PE ~.:...:::.:-=-· -- Tim Alexander, P.E. Report Prepared by: Abdelsalam Masoud, 06/29/2022 Report Reviewed by: Mike Arnold, 06/29/2022 Page 3 of21 2 Executive Summary This report provides the results of an RF power density analysis performed for Verizon at site CAL VERA HILLS in accordance with the Federal Communications Commission (FCC) rules and regulations for RF emissions described in OET Bulletin 65, Edition 97- 01. This report addresses RF safety for two classified groups defined by OET Bulletin 65: Occupational/ Controlled and General Population/ Uncontrolled. Based on the analysis, this site will be Compliant with FCC rules and regulations and Verizon's Signage and Barrier Policy if the mitigation details provided in Table 1 are implemented. -... =-~ ... -• r ACAUTION ' lld\:IJ:?.Et·!tl I I Final Compliant !iii;;::-___ C<i>)j; _ IA~e=:=--1•1"-----J.~l Configuration ---'---,/ I;;. :::;;: ' ,/ -· -J GUIDELINES NOTICE CAUTION WARNING NOC INFO BARRIER/MARKER Access Point(s) ~ [1] * D [] □ [] IZI [2] ** ~ [1] * □ Alpha □ [] D [] □ [] D [] D [] □ Beta D [] D [] D [] D [] D [] □ Gamma D [] D [] D [] D [] D [] □ NOTE: The table represents either the signage/barriers installed/ removed OR items required by the market (if mitigation is not installed by consultant/vendor). * These RF signs should be posted on the Access Gate to the Pole. (See drawing in Section 5.2). ** These RF signs should be installed on the Front and Back of the Pole 18' below the Antenna I centerline. (See drawing in Section 5.2). Specialty Si2n Detail Location NIA Access Point NIA Alpha NIA Beta NIA Gamma NIA NOTE: The tables above represent EXISTING compliance items implemented at this location. Notes/ Additional Compliance Requirements(s): Mitigation is required per the Signage/ Barrier Diagram. Table 1: Mitigation Requirements for Compliance Page 4 of21 2.1 Conclusion and Recommendations • The results of the analysis indicate that the power density levels in the generally accessible areas on the Light Pole Level will not exceed the FCC's MPE limit for General Population. • The results of the analysis indicate that power density levels in the generally accessible areas on the Stadium Light Pole will not exceed the FCC's MPE limit for General Population environments. Notice that the power density levels will exceed the FCC's MPE limit for General Population and Occupational in front of the antennas which it is not generally accessible areas. This area might be accessed in case of maintenance; therefore, mitigation is required per the Signage/ Barrier Diagram. • The max theoretical % MPE is 3461.25% directly in front of the antennas beams at the Stadium Light Pole Elevation Level. • NOC and Guidelines signs need to be posted on the Access Gate to the Pole. Note: Modifications to the site: and/or increases in channel counts or power levels exceeding those listed in this report will require additional evaluation to determine compliance. Page 5 of21 3 Introduction The purpose of this analysis and report is to evaluate the cumulative power density levels of all non-excluded antennas located on the site and identify any areas of concern that require mitigation. This report also assesses the site's compliance with FCC OET Bulletin 65; "Guidelines for Human Exposure to Radio-frequency Electromagnetic Fields". The power density simulation performed for this site utilized RoofMaster® analysis software. All antennas were assigned an operating frequency and transmit power and were deemed to be operating at 100% of their rated output power. 3.1 Site Description: • Site Name: • Street Address: Calvera Hills 2997 Glasgow Dr. Carlsbad, CA 92008 • Latitude: 33° 10' 2.2116" N • Longitude: 117° 17' 58.7004" W • Structure Type: Stadium Light Pole • Structure Height: ± 79.1' AGL • Co-Locators/ Other Antennas: NIA • BTS Equipment Location: The VZW Equipment is located on the Ground. • Access: 1 Page 6 of21 3.2 Site Configuration Being Modeled • This is a Stadium Light Pole application where Verizon antennas are mounted to mounting pipes on the Pole. • This is a Three-Sectors site supporting L TE at 700, 850, 1900, 2100 MHz, 5GNR at 850MHz, CBRS at 3.6 GHz, and C-Band for all sectors. All LTE assumes 4x4 MIMO. • The values of the LTE antenna rad center (58'), C-Band antennas (67.7'), Light Pole Height (10'), and Road Height (-18') are based on the CDs, RFDS, and Google Earth. These values must be verified on the site audit for the post study. • All technologies were evaluated assuming the max number of channels and were running at max power 100% of the time. Page 7 of21 4 Predictive Analysis Details For purposes of this analysis, RoofMaster® was configured to provide an output based on the appropriate MPE limit(s) published in the FCC's guidelines. The antenna information was loaded into RoofMaster®, an MPE predictive analysis tool by Waterford Consultants, LLC. 4.1 Analysis Locations: Number of Elevations Analyzed: 2 • Light Pole Level. • Elevation (Antenna Level). • A study at the Ground level was not required as the study at the Light Pole level shows that the MPE limit is below the General Population MPE limit on the Ground. Page 8 of21 4.2 Antenna Inventory The following table contains the technical data used to simulate the power density that may be encountered with all antennas simultaneously operating at full rated power with the exception of any excluded antennas cited in this document. If co-locator's antennas exist and specific antenna details could not be secured, generic antennas, frequencies, and transmit powers were used for modeling. The assumptions used are based on past ex erience with communications carriers. VZ Alpha_Antl C-Band 3700 5.0 64 0.0 320.0 ERICSSON AIR6449 Various 57.7 Panel 2.8 23.6 11 80 VZ Alpha_Ant2 L700 730 60.0 4 0.5 213.9 COMMSCOPE NNH4SS-6SC-R38 Various 48.0 Panel 8.0 12.7 78 80 VZ Alpha_Ant2 L8SO 880 60.0 4 o.s 213.9 COMMSCOPE NNH4SS-65C-R38 Various 48.0 Panel 8.0 13.4 66 80 VZ Alpha_Ant2 Ll900 1900 80.0 4 0.5 285.2 COMMSCOPE NNH4SS-65C-R38 Various 48.0 Panel 8.0 15.4 66 80 VZ Alpha_Ant2 L2100 2110 40.0 4 0.5 142.6 COMMSCOPE NNH4SS-65C-R38 Various 48.0 Panel 8.0 16.1 62 80 VZ Alpha_Ant2 L2100_3 2170 40.0 4 0.5 142.6 COMMSCOPE NNH4SS-65C-R38 Various 48.0 Panel 8.0 16.1 62 80 VZ Alpha_Ant2 CBRS 3600 5.0 4 0.0 20.0 COMMSCOPE NNH4SS-65C-R38 Various 48.0 Panel 8.0 11.2 60 80 VZBeta-Antl C-Band 3700 s.o 64 0.0 320.0 ERICSSON AIR6449 Various 57.7 Panel 2.8 23.6 11 210 VZ Beta-Ant2 L700 730 60.0 4 0.5 213.9 COMMSCOPE NNH4SS-65C-R3B Various 48.0 Panel 8.0 12.7 78 210 VZ Beta-Ant2 LB50 B80 60.0 4 0.5 213.9 COMMSCOPE NNH4SS-6SC-R3B Various 48.0 Panel 8.0 13.4 66 210 VZ Beta-Ant2 Ll900 1900 80.0 4 0.5 285.2 COMMSCOPE NNH4SS-6SC-R3B Various 48.0 Panel 8.0 lS.4 66 210 VZ Beta-Ant2 L2100 2110 40.0 4 0.5 142.6 COMMSCOPE NNH4SS-6SC-R3B Various 48.0 Panel 8.0 16.1 62 210 VZ Beta-Ant2 L2100_3 2170 40.0 4 0.5 142.6 COMMSCOPE NNH4SS-65C-R38 Various 48.0 Panel 8.0 16.1 62 210 VZ Beta-Ant2 CBRS 3600 5.0 4 0.0 20.0 COMMSCOPE NNH4SS-65C-R3B Various 48.0 Panel 8.0 11.2 60 210 VZ Gamma-Antl C-Band 3700 5.0 64 0.0 320.0 ERICSSON AIR6449 Various 57.7 Panel 2.8 23.6 11 340 VZ Gamma-Ant2 L700 730 60.0 4 0.5 213.9 COMMSCOPE NNH4SS-65C-R3B Various 48.0 Panel 8.0 12.7 78 340 VZ Gamma-Ant2 L850 880 60.0 4 0.5 213.9 COMMSCOPE NNH4SS-65C-R3B Various 48.0 Panel 8.0 13.4 66 340 VZ Gamma-Ant2 Ll900 1900 80.0 4 0.5 285.2 COMMSCOPE NNH4SS-65C-R3B Various 48.0 Panel 8.0 lS.4 66 340 VZ Gamma-Ant2 L2100 2110 40.0 4 0.5 142.6 COMMSCOPE NNH4SS-6SC-R3B Various 48.0 Panel 8.0 16.1 62 340 VZ Gamma-Ant2 L2100_3 2170 40.0 4 0.5 142.6 COMMSCOPE NNH4SS-6SC-R3B Various 48.0 Panel 8.0 16.1 62 340 VZ Gamma-Ant2 CBRS 3600 5.0 4 0.0 20.0 COMMSCOPE NNH4SS-65C-R38 Various 48.0 Panel 8.0 11.2 60 340 The antenna Z-heights listed above are referenced to the Elevation (Antenna level) and Light Pole levels. Page 9 of 21 4.3 RF Emissions Diagram(s) -All Transmitters The following Diagram(s) represent the theoretical spatially averaged Maximum Permissible Exposure (MPE) percentages that are expected for each study's elevation. An additional 1 % Occupational MPE Limit (5% General Population MPE limit) is included to demonstrate where Verizon is a significant contributor to the accessible areas where multiple carriers' transmitters may be present. Ground Reference Plane: Light Pole Level VZW Beta 210° Ground VZWAlpha 80° Ground Pe,c ... MPE Legend D ~-1~ ■ 1~-- • 21li -1tm: D llm:-l!Xm: ■ l!Xm:• OCCl4)000MI lilb S1Aa09 lO k,otirJ,ize IAvo: 10,016Fff(J Mo.V-6.7◄~ Carne, C.otor Code l•v......, I Page 10 of 21 4.4 RF Emissions Diagram(s) -Verizon Transmitters Only The following Diagram(s) represent the theoretical spatially averaged Maximum Permissible Exposure (MPE) percentages that are expected for each study 's elevation. An additional 1 % Occupational MPE Limit (5% General Population MPE limit) is included to demonstrate where Verizon is a significant contributor to the accessible areas where multiple carriers' transmitters may be present. Ground Reference Plane: Light Pole Level VZW Beta 210° Ground VZW Alpha 80° Ground Pe,cer,t MPE Legend D ():(-11t • 1'¥·2lllt ■--1~ D 1(rlX-1inl); • 1oo:n:. O~l.nls SIA<OS 10 loci i,id size IA"V 10to 1GFeet) Mo.V.iue: 6.7◄% Cat11Ct Cabe Code I• Veozon Page 11 of21 5 Signage/ Mitigation 5.1 Signagel Barrier Detail • .,.,a__. ) a Final Compliant --- !fr=--=,.-= Configuration !!:===:..."":..-- GUIDELINES NOTICE Access Point(s) 181 [1] * □ [] Alpha □ [] □ [] Beta □ [] □ [] Gamma □ [] □ [] /.&CAUTION \ A l;--- '-_,/ CAUTION □ [] □ [] □ [] □ [] .., 111~1i&i!l•Y■ I I •I~:-----I '-" ' -------__) '---J C --• WARNING NOC INFO BARRIER/MARKER ~ [2] ** 181 [l ] * □ □ [] □ [] □ □ [] □ [] □ □ [] □ [] □ NOTE: The table represents either the signage/barriers installed/ removed OR items required by the market (if mitigation is not installed by consultant/vendor). • These RF signs should be posted on the Access Gate to the Pole. (See drawing in Section 5.2). ** These RF signs should be installed on the Front and Back of the Pole I 8' below the Antenna I centerline. (See drawing in Section 5.2). Specialty Sien Detail Location NIA Access Point NIA Alpha NIA Beta NIA Gamma NIA NOTE: The tables above represent EXISTING compliance items implemented at this location. Notes/ Additional Compliance Requirements(s): Mitigation is required per the Signage/ Barrier Diagram. Table 2: Mitigation Requirements for Compliance Page 12 of21 5.2 Signagel Barrier Diagram Lights 18' Stadium Light Pole Ground Warning signage (x2) needs to be installed on the Front and Back of the Pole 18' below the Antenna 1 centerline . . . ...... .... ~ ..... -----------·-·--·---·--... _____ _ ·------ NOC and Guidelines signs need to be posted on the Access Gate to the Pole. Page 13 of 21 6 Conclusions and Recommendations • The results of the analysis indicate that the power density levels in the generally accessible areas on the Light Pole Level will not exceed the FCC's MPE limit for General Population. • The results of the analysis indicate that power density levels in the generally accessible areas on the Stadium Light Pole will not exceed the FCC's MPE limit for General Population environments. Notice that the power density levels will exceed the FCC's MPE limit for General Population and Occupational in front of the antennas which it is not generally accessible areas. This area might be accessed in case of maintenance; therefore, mitigation is required per the Signage/ Barrier Diagram. • The max theoretical % MPE is 3461.25% directly in front of the antennas beams at the Stadium Light Pole Elevation Level. • NOC and Guidelines signs need to be posted on the Access Gate to the Pole. Note: Modifications to the site; and/or increases in channel counts or power levels exceeding those listed in this report will require additional evaluation to determine compliance. Page 14 of21 7 Appendix A: FCC Compliance and RF Safety Policies In August of 1997, the FCC published OET Bulletin 65 Edition 97-01 to regulate methods for evaluating compliance with FCC guidelines for human exposure to radiofrequency (RF) electromagnetic fields. The FCC guidelines for human exposure to RF electromagnetic fields incorporate two categories of limits; namely "Controlled" (a.k.a. Occupational) and "Uncontrolled" (a.k.a. General Public). The guidelines offer suggested methods for evaluating fixed RF transmitters to ensure that the controlled and uncontrolled limits deemed safe by the FC for human exposure are not exceeded. OET Bulletin 65 recommended guidelines are intended to allow an applicant to "make a reasonably quick determination as to whether a proposed facility is in compliance with the limits." In addition, the guidelines offer alternate supplementary considerations and procedures such as field measurements and more detailed analysis that should be used for multiple emitter situations. These guidelines define RF as emissions in the frequency range of 300 kHz to 100 GHz. The FCC define Maximum Permissible Exposure (MPE) limits within this frequency range based on limits recommended by the National Council on Radiation Protection and Measurement, the Institute of Electrical and Electronics Engineers (IEEE), and by the American National Standards Institute (ANSI). The specific MPE limits defined by the FCC are as follows: Frequency Range [MHz] 0.3-3.0 3.0-30 30-300 300-1,500 1,500-100,000 Frequency Range [MHz) 0.3-3.0 3.0-30 30-300 300 -1,500 1,500 -100,000 f = frequency Limits for Occupational/Controlled Exposure Electric Field Magnetic Field Power Density Strength (E) [Vim] Strength (H) [Alm] (S) [mW/Cm"2] 614 1.63 100* 1842/f 4.89/f 900/f112* 61.4 0.163 1 f/300 5 Averaging Time IEl"2, IHl"2 or S [minutes] 6 6 6 6 6 Limits for General Population/Uncontrolled Exposure Electric Field Magnetic Field Power Density Averaging Time IEl"2, Strength (E) [Vim] Strength (H) [Alm] (S) [mW/Cm"2] IHl"2 or S [minutes] 614 1.63 100* 30 842/f 2.19/f 180/f112* 30 27.5 0.073 0.2 30 f/1500 30 1 30 *Plane-wave equivalent power density The FCC states that "Occupational/ Controlled limits apply in situations in which persons are exposed as a consequence of their employment provided those persons are fully aware of the potential for exposure and can exercise control over their exposure. Limits for Occupational/ Controlled exposure also apply in situations when an individual is Page 15 of21 transient through a location where Occupational/ Controlled limits apply provided he or she is made aware of the potential for exposure." For General Population/ Uncontrolled limits, the FCC states that "General Population/ Uncontrolled exposures apply in situations in which the general public may be exposed, or in which persons that are exposed as a consequence of their employment may not fully be aware of the potential for exposure or cannot exercise control over their exposure." For purposes of this analysis, all limits are evaluated against the Power Density limits. Typical guidelines for determining whether Occupational/ Controlled limits can be applied include ensuring the environment (such as a rooftop) as limited/controlled access via locked doors or physical barrier that are preferably controlled by a landlord that is aware of the situation and can inform anyone going through the locked door of the existence of the RF emissions. Such notification/awareness is typically accomplished by means of signage on the door, or other access to the area of concern, as well as signage on or near the antennas. Examples of such signs include the following: GUIDELINES NOTICE CAUTION WARNING This sign will inform anyone of the basic precautions to follow when entering an area with transmitting radiofrequency This sign indicates that RF emissions may exceed the FCC General Population MPE limit. This sign indicates that RF emissions may exceed the FCC Occupational MPE limit. This sign indicates that RF emissions may exceed at least 1 Ox the FCC Occupational MPE limit. e ui ment. .. NIJTICl.o __ .__, m - ---- NOC INFORMATION Information signs are used as a means to provide contact information for any ,•,d• ......... n.il•IICCUl,cat•• questions or concerns. They will include specific cell site identification ___ _...,._ information and the Verizon Wireless Network Operations Center phone -------number. - Standards for when to use each of the above signs for Occupational situations are as follows : No sign required: <200/o of Occupational MPE Blue Sign, Notice: 200/o to < 1000/o of MPE Yellow Sign, Caution: 1000/o to <10000/o of MPE Red Sign, Warning: ;?:10000/o of MPE All MP E references are to the FCC Occupational limits. Page 16 of21 8 Appendix B: Overview of RoofMaster® Functions and Assumptions RoofMaster® is a RF Compliance software package designed to enable the analysis, assessment and mitigation of communications sites with respect to human exposure to radiofrequency electromagnetic fields. RoofMaster® was developed in 2008 by Waterford Consultants to support compliance assessments performed at single and multi-operator wireless locations throughout North America and has been in service since 2008. Real-world experience in evaluating thousands of base station installations is reflected in the RoofMaster® design approach. This document provides a guide for creating simulations of RF hazard conditions through the characterization of antenna systems and site features and through FCC-specified computational analysis. On any structure, one may encounter antennas installed by wireless service providers, public safety and other FCC-licensed and unlicensed operators. Siting constraints have resulted in diverse and complex environments accessible to people performing a variety of activities around these antennas. RoofMaster® supports the characterization of these locations to convey important information regarding RF sources and accessible areas necessary to evaluate the potential for human exposure to hazardous levels of RF energy. RoofMaster® supports the depiction of communications sites through the display of construction drawing or aerial photography image files as well as providing line drawing tools. These representations are scalable to enable the modeling of any location. RoofMaster® utilizes a three-dimensional spatial framework consisting of a 1000 x 1000 grid with unlimited vertical dimensions necessary for the positioning of antennas and modeling of RF conditions at each grid point throughout the space. Predictive analysis is performed on a study plane at a specified elevation. The subsequent sections of this guide provide the steps necessary to create a site representation and conduct these studies. RoofMaster® employs several power density prediction models based on the computational approaches set forth in the Federal Communications Commission's Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields, OET Bulletin 65. This guideline utilizes several antenna and operational parameters in calculating the power density contributions from each emitter at specified points throughout the study space. RoofMaster® enables antennas to be fully defined in site specific aspects as well as through the use of a library of manufacturer data. The parameters include: Page 17 of21 § Antenna model § Radiation patterns § Aperture length § Gain § Beamwidth § Antenna radiation center § Azimuth § Mechanical downtilt § Location § Frequency § Power into antenna In OET-65, the Cylindrical Model is presented as an approach to determine the spatially averaged power density in the near field directly in front of an antenna. In order to implement this model in all directions, RoofMaster® utilizes the antenna manufacturer horizontal pattern data. Additionally, RootMaster® incorporates factors that reduce the power density by the inverse square of horizontal and vertical distance beyond the near field region. Power density is calculated as follows: • S is the spatially averaged power density value • R is the horizontal distance meters to the study point • h is the aperture length in meters • Pin is power into the antenna input port in Watts RoofMaster® Implementation: • Gtt is gain offset to study point as specified in manufacturer horizontal pattern • Pin is adjusted by the portion of the antenna aperture in the 0-6 ft. vertical study zone • Hr accounts for 1/R2 Far Field roll off which starts at 2*h • Yr accounts for 1/ (vertical distance)2 roll off from antenna bottom to the top of the 0-6 ft. study zone ( or antenna top to bottom of 0-6 ft. study zone) Page 18 of21 z R•Horizontal Distance Far Field ----···-···-'---------------------------....... .:.0::.11_ Horiiontal Distance Page 19 of21 9 References FCC (1997). "Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields"; Federal Communications Commission; Office of Engineering and Technology, OET Bulletin 65, Edition 97-01, August. Waterford Consultants, LLC (2008). Consultants, LLC. RoofMaster® User Guide, Waterford Page 20 of21 10 Limited Warranty Pramira, Inc. warrants that this analysis was performed in good faith using the methodologies and assumptions covered in this report and that data used for the analysis and report were obtained by Pramira, Inc. employees or representatives via site surveys or research of Verizon's available information. In the event that specific third-party details were not available, best efforts were made to use assumptions that are based on industry experience of various carriers' standards without violating any confidential information obtained under non-disclosure terms. Pramira, Inc. also warrants that this analysis was performed in accordance with industry acceptable standards and methods. There are no other warranties, express or implied, including but not limited to, the implied warranties of merchantability and fitness for a particular purpose, relating to this agreement or to the services rendered by Pramira hereunder. In no event shall Pramira be held liable to Verizon, or to any third party, for any indirect, special, incidental, or consequential damages, including but not limited to loss of profits, loss of data, loss of good will, and increased expenses. In no event shall Pramira be liable to Verizon for damages, whether based in contract, tort, negligence, strict liability, or otherwise, exceeding the amount payable hereunder for the services giving rise to such liability. Page 21 of21