2020-11-16T17:56:39-06:00 2019-12-31 260794367 UHY ADVISORS MID-ATLANTIC MD INC 8601 ROBERT FULTON DRIVE SUITE 210 COLUMBIA MD 21046 990 2019-01-01 730529079 INTERSTATE NATURAL GAS ASSN OF AMERICA INTE 2022165900 20 F STREET NW NO 450 WASHINGTON DC 20001 AMY ANDRYSZAK PRESIDENT & CEO 2022165900 2020-11-16 1 NANCY JOHNSON P01593478 4107205220 209.99.101.4 2020-11-16 17:17:33 ES P DA39A3EE5E6B4B0D3255BFEF95601890AFD80709 9971D89881080ED63BCE94300AA46B5562DADC38 2019 2022-01-07 14:23:13Z AMY ANDRYSZAK 20 F STREET NW WASHINGTON DC 20001 17529742 0 X WWW.INGAA.ORG X 1944 DC INGAA IS AN ADVOCACY ORGANIZATION THAT REPRESENTS THE INTERSTATE NATURAL GAS PIPELINE INDUSTRY IN THE UNITED STATES. INGAA REPRESENTS THE INTERESTS OF ITS MEMBERS THROUGH COMMENTS ON RULEMAKINGS AND OTHER REGULATORY INITIATIVES UNDERTAKEN BY FEDERAL AGENCIES WITH JURISDICTION OVER ITS MEMBER COMPANIES' ACTIVITIES OR WHOSE ACTIONS OTHERWISE AFFECT ITS MEMBER COMPANIES, TESTIMONY FILED WITH COMMITTEES OF THE UNITED STATES CONGRESS AND, ON OCCASION, THROUGH PARTICIPATION IN FEDERAL AND STATE JUDICIAL PROCEEDINGS IN WHICH ITS MEMBERS' COLLECTIVE INTERESTS ARE AT STAKE. 27 27 21 673 0 0 0 0 8250408 8999140 460038 1412418 0 0 8710446 10411558 0 0 0 0 3618357 3896100 0 0 0 3626951 4307181 7245308 8203281 1465138 2208277 13077877 15017787 5539283 4173608 7538594 10844179 X INGAA IS AN ADVOCACY ORGANIZATION THAT REPRESENTS THE INTERSTATE NATURAL GAS PIPELINE INDUSTRY IN THE UNITED STATES. INGAA REPRESENTS THE INTERESTS OF ITS MEMBERS THROUGH COMMENTS ON RULEMAKINGS AND OTHER REGULATORY INITIATIVES UNDERTAKEN BY FEDERAL AGENCIES WITH JURISDICTION OVER ITS MEMBER COMPANIES' ACTIVITIES OR WHOSE ACTIONS OTHERWISE AFFECT ITS MEMBER COMPANIES, TESTIMONY FILED WITH COMMITTEES OF THE UNITED STATES CONGRESS AND, ON OCCASION, THROUGH PARTICIPATION IN FEDERAL AND STATE JUDICIAL PROCEEDINGS IN WHICH ITS MEMBERS' COLLECTIVE INTERESTS ARE AT STAKE.\ 0 0 OPERATIONS, SAFETY AND ENVIRONMENT: INGAA FOCUSED ON THE PROPOSED US DEPARTMENT OF TRANSPORTATION RULEMAKING TO IMPLEMENT THE CONGRESSIONAL MANDATES AFFECTING NATURAL GAS TRANSMISSION PIPELINES IN THE REAUTHORIZATION OF THE PIPELINE SAFETY ACT.INGAA REPRESENTED ITS MEMBERS' INTERESTS IN RESPONSE TO EXECUTIVE BRANCH INITIATIVES INTENDED TO IMPROVE THE EFFICIENCY OF THE FEDERAL PERMITTING PROCESS MORE EFFICIENT. THIS INCLUDED RULEMAKING COMMENTS SUBMITTED TO THE ENVIRONMENTAL PROTECTION AGENCY, THE WHITE HOUSE COUNCIL ON ENVIRONMENTAL QUALITY, AND OTHER AGENCIES.INGAA PARTICIPATE ACTIVELY IN INITIATIVES WITH INDUSTRY GROUPS AND FEDERAL GOVERNMENT PARTNERS TO ENHANCE THE PHYSICAL AND CYBER SECURITY OF NATURAL GAS PIPELINES. THIS INCLUDED PARTICIPATION IN THE OIL AND NATURAL GAS SECTOR COORDINATING COUNCIL, PARTNERSHIP WITH THE DOWNSTREAM NATURAL GAS ISAC, AND SUPPORTING THE UPDATE OF RELEVANT INDUSTRY CONSENSUS STANDARDS. REGULATORY: INGAA FILED EXTENSIVE COMMENTS IN RESPONSE TO PROCEEDINGS INITIATED BY THE FEDERAL ENERGY REGULATORY COMMISSION. THESE INCLUDED THE PROCEEDINGS INITIATED IN RESPONSE TO THE TAX CUTS AND JOBS ACT REGARDING IMPLEMENTATION OF THE LOWER CORPORATE INCOME TAX RATES IN INTERSTATE NATURAL GAS PIPELINE RATES AND A NOTICE OF INQUIRY ON THE COMMISSION'S POLICY FOR AUTHORIZING NEW PIPELINES. INGAA FILED AMICUS BRIEFS IN SUPPORT OF MEMBER COMPANIES INVOLVED IN APPELLATE COURT LITIGATION CONCERNING APPROVALS AND PERMITS NEEDED TO CONSTRUCT INTERSTATE NATURAL GAS PIPELINES. INGAA REMAINED ACTIVE ON MATTERS INVOLVING NATURAL GAS-ELECTRIC POWER INTEGRATION BEFORE THE COMMISSION AND IN OUTREACH WITH ELECTRIC TRANSMISSION OPERATORS AND OTHER STAKEHOLDERS. LEGISLATIVE: INGAA SUPPORTS LEGISLATIVE POLICES THAT PROMOTE THE DEVELOPMENT OF NATURAL GAS INFRASTRUCTURE, AND THE SAFE, EFFICIENT OPERATION OF NATURAL GAS PIPELINES. INGAA JOINED WITH OTHER LIKE- MINDED STAKEHOLDERS IN ADVOCATING THESE POLICIES TO THE US CONGRESS. 0 0 0 1 0 0 0 0 0 1 0 0 0 1 1 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 0 0 0 0 0 0 0 0 0 1 0 0 1 X 29 0 1 21 1 0 0 0 0 0 0 0 0 1 0 X 27 27 1 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 DC X INTERSTATE NATURAL GAS ASSN OF AMERICA 2022165900 20 F STREET NW SUITE 450 WASHINGTON DC 20001 CHAD ZAMARIN BOARD MEMBER 3.00 X 0 0 0 CRYSTAL HETER BOARD MEMBER 2.00 X 0 0 0 DAVID SLATER BOARD MEMBER 2.00 X 0 0 0 GEORGIA CARTER BOARD MEMBER 2.00 X 0 0 0 JEFF BRUNER BOARD MEMBER 2.00 X 0 0 0 JEFF TIETBOHL BOARD MEMBER 2.00 X 0 0 0 JIMMY STATON BOARD MEMBER 2.00 X 0 0 0 JOE HARTZ BOARD MEMBER 2.00 X 0 0 0 JOEY MAHMOUD BOARD MEMBER 2.00 X 0 0 0 JOSEPH OATES BOARD MEMBER 2.00 X 0 0 0 MICHAEL MCMAHON BOARD MEMBER 2.00 X 0 0 0 PAUL RUPPERT BOARD MEMBER 2.00 X 0 0 0 PETER TUMMINELLO BOARD MEMBER 2.00 X 0 0 0 ROGER THORPE BOARD MEMBER 2.00 X 0 0 0 TINA FARACA BOARD MEMBER 2.00 X 0 0 0 TJ TUSCAI BOARD MEMBER 3.00 X 0 0 0 TODD NORMANE BOARD MEMBER 2.00 X 0 0 0 TREVOR HASTINGS BOARD MEMBER 2.00 X 0 0 0 VICTOR GAGLIO BOARD MEMBER 2.00 X 0 0 0 KIM WATSON BOARD MEMBER 2.00 X 0 0 0 SARAH J MUGEL ESQ BOARD MEMBER 2.00 X 0 0 0 THOMAS E BENNETT BOARD MEMBER 2.00 X 0 0 0 WILLIAM T YARDLEY BOARD MEMBER 2.00 X 0 0 0 PETER KENNY BOARD MEMBER 2.00 X 0 0 0 DARREN MARINE BOARD MEMBER 2.00 X 0 0 0 JC THOMAS BOARD MEMBER 2.00 X 0 0 0 STAN CHAPMAN BOARD MEMBER 2.00 X 0 0 0 DONALD F SANTA PRESIDENT & CEO 30.25 6.00 X 1510249 79487 351776 IRYNA BAUKUNOVICH CONTROLLER 29.00 7.25 X 91046 30349 9561 JOAN DRESKIN-JACKSON VP/GENERAL COUNSEL/SECRETA 36.25 X 503161 0 55375 MARTIN EDWARDS III VP LEGISLATIVE AFFAIRS 36.25 X 323905 0 25510 NICHOLE REYNOLDS VP LEGISLATIVE AFFAIRS 36.25 X 154544 0 5275 CHRISTOPHER OSMAN DIRECTOR OF OPERATIONS 36.25 X 209722 0 12384 SANDRA SNYDER REGULATORY ATTORNEY FOR EN 36.25 X 213692 0 14749 AMMAAR JOYA REGULATORY ATTORNEY 36.25 X 129163 0 9378 REBECCA GAGLIOSTRO DIRECTOR OF SECURITY 36.25 X 118368 0 6131 3253850 109836 490139 8 0 1 0 FTI CONSULTING 88 PINE STREET 32ND FLOOR NEW YORK NY 10005 CONSULTING 538124 BRACEWELL LLP 2001 M STREET NW SUITE 900 WASHINGTON DC 20036 CONSULTING 286588 CGCN GROUP LLC 1101 K STREET NW SUITE 800 WASHINGTON DC 20005 PROFESSIONAL SERVICES 240498 CULTUREIQ 200 W 41ST ST 14TH FLOOR NEW YORK NY 10036 PLATFORM LICENSE & SHARED COSTS 186220 FORBES TATE PARTNERS LLC 777 6TH ST NW 8TH FLOOR WASHINGTON DC 20001 REPRESENTATION 180000 5 MEMBERSHIP DUES 900099 8612709 8612709 PROJECT REVENUE 900099 386431 386431 8999140 347000 347000 8183602 7118184 1065418 1065418 1065418 10411558 8999140 0 1412418 2903799 363372 301452 133121 194356 40422 23500 692576 39009 316998 32590 12063 377855 97437 370121 91153 65300 RESEARCH & PROGRAM ACTI 1499470 PUBLIC RELATIONS 549249 PUBLICATIONS & SUBSCRIP 46424 REPAIRS & MAINTENANCE 24009 29005 8203281 1335433 2481824 357981 362365 434402 109030 123599 1724283 1431390 384046 292893 10510053 11645263 18969 39806 13077877 15017787 449871 353830 125631 114500 4963781 3705278 5539283 4173608 X 7538594 10844179 7538594 10844179 13077877 15017787 X 2208277 138809 -20226 978725 X X 0 1 X 1 0 0 0 1 8612709 1071586 541658 1613244 1205779 407465 1083543 835612 247931 640740 595778 44962 292893 RETIREMENT LIABILITIES 3430870 DEFERRED RENT LIABILITY 274408 3705278 X PART X, LINE 2: THE INCOME TAX POSITIONS TAKEN BY THE ASSOCIATION FOR ANY YEARS OPEN UNDER THE VARIOUS STATUTES OF LIMITATION ARE THAT THE ASSOCIATION CONTINUES TO BE EXEMPT FROM INCOME TAXES AND THAT THE ASSOCIATION HAS PROPERLY REPORTED UNRELATED BUSINESS INCOME THAT IS SUBJECT TO INCOME TAXES. THE ASSOCIATION BELIEVES THAT THERE ARE NO TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN THAT WOULD SIGNIFICANTLY INCREASE UNRECOGNIZED TAX BENEFITS WITHIN 12 MONTHS OF THE REPORTING DATE. X 1 1 X X X X 0 1 0 DONALD F SANTA PRESIDENT & CEO 1096190 57694 414059 21793 0 0 295640 15560 38547 2029 1844436 97076 0 300000 JOAN DRESKIN-JACKSON VP/GENERAL COUNSEL/SECRETA 344842 0 155673 0 2646 0 11200 0 44175 0 558536 0 0 0 MARTIN EDWARDS III VP LEGISLATIVE AFFAIRS 290938 0 32738 0 229 0 1486 0 24024 0 349415 0 0 0 NICHOLE REYNOLDS VP LEGISLATIVE AFFAIRS 104544 0 50000 0 0 0 0 0 5275 0 159819 0 0 0 CHRISTOPHER OSMAN DIRECTOR OF OPERATIONS 176120 0 33409 0 193 0 6698 0 5686 0 222106 0 0 0 SANDRA SNYDER REGULATORY ATTORNEY FOR EN 177519 0 35566 0 607 0 6425 0 8324 0 228441 0 0 0 PART I, LINE 4B DONALD SANTA HAD AN AGREEMENT WITH INGAA FOR AN EARLY RETIREMENT BENEFIT. AMOUNTS ARE INCLUDED IN PART II OF SCHEDULE J. DONALD SANTA PARTICIPATED IN A DEFERRED INCENTIVE COMPENSATION PLAN, AMOUNT IS INCLUDED IN PART II, COLUMN "C" OF SCHEDULE J. FORM 990, PART V, LINE 2A, COMMON PAYMASTER INGAA SERVES AS THE COMMON PAYMASTER FOR ITSELF AND THE INGAA FOUNDATION, INC. INGAA REPORTED 21 EMPLOYEES ON THE FEDERAL FORM W-3 FOR THE YEAR 2019. TWO OF THOSE 21 EMPLOYEES' TIME WAS ALLOCATED BETWEEN THE ENTITIES. FORM 990, PART VI, SECTION A, LINE 2 THROUGH NORMAL COURSE OF BUSINESS, ONEOK AND COMPANIES REPRESENTED ON THE INGAA BOARD ARE INVOLVED IN VARIOUS BUSINESS ACTIVITIES SUCH AS SERVICE CONTRACTS, JOINT VENTURES, ETC. WITH THE FOLLOWING COMPANIES: PHILL MAY (ONEOK, INC.) ENABLE MIDSTREAM, NEXTERA ENERGY RESOURCES, PIEDMONT NATURAL GAS, SOUTHERN COMPANY GAS, TRANSCANADA, THE WILLIAMS COMPANIES, INC. FORM 990, PART VI, SECTION A, LINE 6 NATURAL GAS PIPELINE COMPANIES (SHALL INCLUDE ANY PERSON, FIRM OR CORPORATION ENGAGED IN THE PIPELINE TRANSPORTATION OF NATURAL GAS IN NORTH AMERICA WHOSE ACTIVITIES AND INTERESTS ARE DEEMED BY THE BOARD OF DIRECTORS TO BE CONSISTENT WITH THE OBJECTIVES OF THE ASSOCIATION), SHALL BE ELIGIBLE FOR MEMBERSHIP WITH THE RIGHT TO VOTE AT MEETINGS OF THE MEMBERS, THROUGH THEIR ACCREDITED REPRESENTATIVES. FORM 990, PART VI, SECTION A, LINE 7A ACCORDING TO ARTICLE IV, SECTION 3 OF THE BYLAWS OF INGAA, EACH MEMBER OF THE ASSOCIATION IN GOOD STANDING AND ELIGIBLE TO VOTE SHALL BE ENTITLED TO ONE (1) VOTE ON ALL MATTERS PROPERLY BEFORE THE MEETING OF THE MEMBERS. THE VOTE OF ANY MEMBER OF THE ASSOCIATION MAY BE CAST BY ITS REPRESENTATIVE OR PROXY. ANY SUCH PROXY MUST BE FURNISHED IN WRITING. ANY PROXY MAY BE REVOKED AND WITHDRAWN AT ANY TIME BY THE MEMBER WHO CONFERRED SUCH PROXY BY SO NOTIFYING, IN WRITING, THE PRESIDENT AND THE PERSON TO WHOM THE PROXY WAS ORIGINALLY GIVEN. NO PERSON OTHER THAN A DULY QUALIFIED MEMBER ENTITLED TO VOTE AND IN GOOD STANDING OR A PERSON PROPERLY AUTHORIZED TO REPRESENT SUCH A MEMBER CAN HOLD AND EXERCISE A PROXY FROM ANY MEMBER OF THE ASSOCIATION. ANY ACTION REQUIRED OR PERMITTED TO BE TAKEN AT ANY MEETING OF MEMBERS MAY, EXCEPT AS OTHERWISE REQUIRED BY LAW OR THE CERTIFICATE OF INCORPORATION, BE TAKEN WITHOUT A MEETING, WITHOUT PRIOR NOTICE AND WITHOUT A VOTE, IF A CONSENT IN WRITING, SETTING FORTH THE ACTION SO TAKEN, SHALL BE SIGNED BY THE MEMBERS HAVING NOT LESS THAN THE MINIMUM NUMBER OF VOTES THAT WOULD BE NECESSARY TO AUTHORIZE OR TAKE SUCH ACTION AT A MEETING AT WHICH ALL MEMBERS ENTITLED TO VOTE THEREON WERE PRESENT AND VOTED, AND THE WRITING OR WRITINGS ARE FILED WITH THE PERMANENT RECORDS OF THE ASSOCIATION. PROMPT NOTICE OF THE TAKING OF CORPORATE ACTION WITHOUT A MEETING BY LESS THAN UNANIMOUS WRITTEN CONSENT SHALL BE GIVEN TO THOSE MEMBERS WHO HAVE NOT CONSENTED IN WRITING. FORM 990, PART VI, SECTION A, LINE 7B ACCORDING TO ARTICLE VII OF THE BYLAWS OF INGAA, THE BOARD MAY CREATE ONE OR MORE COMMITTEES OF THE BOARD ("BOARD COMMITTEES") THAT CONSIST OF ONE OR MORE DIRECTORS. THE CREATION OF A BOARD COMMITTEE, AND APPOINTMENT OF DIRECTORS TO IT, MUST BE APPROVED BY A MAJORITY OF ALL THE DIRECTORS THEN IN OFFICE. THE BOARD MAY DESIGNATE ONE OR MORE DIRECTORS AS ALTERNATE MEMBERS OF ANY BOARD COMMITTEE, WHO MAY REPLACE ANY ABSENT OR DISQUALIFIED MEMBER AT ANY MEETING. BOARD COMMITTEES SHALL HAVE AND MAY EXERCISE ALL THE POWERS AND AUTHORITY OF THE BOARD IN THE MANAGEMENT OF THE BUSINESS AND AFFAIRS OF THE ASSOCIATION TO THE EXTENT PROVIDED IN THE RESOLUTION OF THE BOARD OR IN THE BYLAWS; BUT NO BOARD COMMITTEE SHALL HAVE THE POWER OR AUTHORITY IN REFERENCE TO: (A) AMENDING THE CERTIFICATE OF INCORPORATION OR BYLAWS, (B) ADOPTING AN AGREEMENT OF MERGER OR CONSOLIDATION, (C) RECOMMENDING TO THE MEMBERS THE SALE, LEASE OR EXCHANGE OF ALL OR SUBSTANTIALLY ALL OF THE ASSOCIATION'S ASSETS, (D) RECOMMENDING TO THE MEMBERS A DISSOLUTION OF THE ASSOCIATION OR A REVOCATION OF A DISSOLUTION, (E) ANY OTHER ACTIONS WHICH REQUIRE THE APPROVAL OF THE BOARD UNDER APPLICABLE LAW OR THESE BYLAWS, (F) FILLING VACANCIES IN THE BOARD OR ANY COMMITTEE, (G) ELECTING, APPOINTING OR REMOVING ANY MEMBER OF ANY COMMITTEE OR ANY DIRECTOR OR OFFICER, OR (I) AMENDING OR REPEALING ANY RESOLUTION OF THE BOARD. EACH BOARD COMMITTEE SHALL KEEP MINUTES OF ITS PROCEEDINGS, AND ACTIONS TAKEN BY A BOARD COMMITTEE SHALL BE REPORTED TO THE BOARD. FORM 990, PART VI, SECTION B, LINE 11B AN ELECTRONIC VERSION OF FORM 990 IS DISTRIBUTED TO ALL BOARD MEMBERS PRIOR TO THE BOARD MEETING FOR THEIR REVIEW. APPROVAL OF THE 990 IS LISTED AS AN AGENDA ITEM FOR THE BOARD MEETING; AFTER DISCUSSION, A MOTION WAS REQUESTED FOR PERMISSION TO FILE THE FORM 990 AS WRITTEN (OR WITH APPROVED CHANGES) AND PASSED BY VOICE VOTE. FORM 990, PART VI, SECTION B, LINE 12C INGAA HAS TWO CONFLICT OF INTEREST POLICIES. ONE POLICY APPLIES TO ALL INGAA EMPLOYEES AND THE OTHER POLICY APPLIES TO KEY INGAA EMPLOYEES AND MEMBERS OF THE BOARD OF DIRECTORS. INGAA STAFF AND THE BOARD WERE BRIEFED ON THE POLICIES AND WERE PROVIDED WITH EXAMPLES OF THE TYPES OF SITUATIONS THAT COULD BE DEEMED TO BE "CONFLICTS OF INTEREST" THAT WOULD NEED TO BE REPORTED TO EITHER THE PRESIDENT, OR OTHER MANAGEMENT. THE ASSOCIATION MAINTAINS DOCUMENTATION MEMORIALIZING THAT ALL STAFF AND BOARD MEMBERS HAVE EXECUTED DECLARATIONS STATING THAT THEY HAVE READ AND AGREE TO ABIDE BY THE CONFLICT OF INTEREST POLICIES. FORM 990, PART VI, SECTION B, LINE 15 INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA RETAINS AN INDEPENDENT CONSULTANT TO PERFORM A MARKET ANALYSIS OF INGAA'S COMPENSATION PRACTICE FOR SENIOR EXECUTIVES RELATIVE TO COMPARABLE POSITIONS WITHIN SIMILAR ORGANIZATIONS. THE PRESIDENT OF INGAA PROVIDES THE COMPENSATION COMMITTEE WITH DOCUMENTATION SUPPORTING RECOMMENDED BASE SALARY ADJUSTMENTS AND RECOMMENDED INCENTIVE COMPENSATION AWARDS FOR STAFF BASED UPON THE OVERALL PERFORMANCE OF THE ORGANIZATION MEASURED AGAINST ITS ANNUAL BOARD-APPROVED ACTION PLAN AND THE PERFORMANCE OF INDIVIDUAL EXECUTIVES MEASURED AGAINST THEIR ANNUAL GOALS. THE COMMITTEE ALSO EVALUATES THE PERFORMANCE OF THE PRESIDENT BASED ON THESE CRITERIA. THE COMPENSATION COMMITTEE MAKES A FINAL DECISION ON BASE SALARY AND INCENTIVE COMPENSATION FOR THE PRESIDENT AND ALL SENIOR EXECUTIVES WHO REPORT DIRECTLY TO THE PRESIDENT. THE MEMBERSHIP OF THE COMPENSATION COMMITTEE IS IDENTICAL TO THE MEMBERSHIP OF THE BOARD STEERING COUNCIL. FORM 990, PART VI, SECTION C, LINE 19 INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA DOES NOT MAKE ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY OR FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC. THE ASSOCIATION DOES, UPON REQUEST, SHARE FINANCIAL STATEMENTS WITH BANKS, INSURANCE COMPANIES AND OTHER VENDORS FOR THE PURPOSE OF OBTAINING CREDIT. FORM 990, PART XI, LINE 9: PENSION-RELATED CHANGES OTHER THAN NET PERIODIC PENSION COSTS 978,725. PAGE 12 PART XII, LINE 2C NO CHANGES TO THE OVERSIGHT OR SELECTION PROCESS HAS BEEN MADE DURING THE TAX YEAR. THE INGAA FOUNDATION 20 F STREET SUITE 450 WASHINGTON DC 20001 521667696 DC 501(C)(6) NO 0 THE INGAA PAC 20 F STREET SUITE 450 WASHINGTON DC 20001 521911400 DC 527 NO 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0