Given the task definition and input, reply with output. In this task, you're given a statement, and three sentences as choices. Your job is to determine which sentence clearly disagrees with the statement. Indicate your answer as '1', '2', or '3' corresponding to the choice number of the selected sentence.

Statement: This estimate is the mean of a distribution fitted to the estimates from 26 value-of-life studies identified in the Section 812 reports as applicable to policy analysis. Choices: 1. The estimate is the mean of 5 value of life studies. 2. The estimate is based off of the average fitted to the studies. 3. The estimate has based off of the given values.
1