HomeMy WebLinkAbout20200813Falls Water to Staff 1-40.pdf
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 1
REQUEST NO. 1: Please provide a schedule of all additions and retirements to Plant in
Service since the beginning of 2012, including installation date, account, installed cost,
and estimated depreciable life, that were not included in the "2020 Depr" tab of the 2020
Rate Case Exhibits.
Response:
Please see FLS-W-20-03 IPUC DR 1 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 2
REQUEST NO. 2: Please provide all journal entries related to additions and retirements
to Plant in Service since the beginning of 2012.
Response:
The Company has provided Staff with an accountant’s copy of its 2020 QuickBooks Pro
company file that contains transactions through December 31, 2019. Staff may view all
of the requested journal entries from this file.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 3
REQUEST NO. 3: Please provide the running balance and all deposits and withdrawals
from the special plant reserve fund since its inception in Order No. 32663 in Case No.
FLS-W-12-01.
Response:
Please see FLS-2-20-03 IPUC DR 3 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 6
REQUEST NO. 6: What are the SCADA functions in the rate base addition shown in
Exhibit 1, Column G?
Response:
Final connection of Well 10 SCADA had not been completed. The invoice from Exhibit
1, Column G is for work done to help get the well site to communicate with the SCADA
computer. The invoice from the vendor was not received until early January 2020. The
communication between Well 10 and the SCADA computer was finalized in November
2019.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 4
REQUEST NO. 4: Please provide a copy of the Company's Chart of Accounts and any
related instruction material.
Response:
Please see FLS-W-20-03 IPUC DR 4 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 7
REQUEST NO. 7: In Final Order No. 33863, the Commission ordered the Company to
"...notify the Commission when on-site power is installed at the well and the cost of any
such installation"
Please provide the following information:
a. The make, model, power rating, equipment cost, and installation costs of this
generator.
b. The date on which the generator became fully operational.
c. Reports of any tests or inspections conducted by the DEQ indicating the status of the
generator (e.g. results of the Company's latest DEQ Sanitary Survey).
Response:
The Company should have filed the separate notification of the backup generator
installation being completed in March 2020 and apologizes for the oversight.
The generator for Well 10 is a Caterpillar Model C7.1 KW 175 generator. A variable
frequency drive (VFD) was needed for the well motor to provide a soft start for the 150
hp pump motor.
Cost of generator and VFD:
Generator $47,123.00
Manual Transfer Switch $14,459.62
VFD $29,776.29
Total $91,358.91
The generator was delivered August 28, 2019. Full utilization of the generator was
delayed until the manual transfer switch could be installed on March 27, 2020.
The Company has no documentation from DEQ indicating the status of the generator.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 8
REQUEST NO. 8: Please list any additions to rate base or expenses in 20l9 that are
related to abandoned projects (such as expenses for engineering and preliminary work
for a project that is stopped before it is completed).
Response:
No projects were abandoned in 2019. Therefore, no costs added to rate base or to
expenses relate to abandoned projects.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 10
REQUEST NO. 10: Please summarize all benefits and retirement plans provided to any
classification of Company employees. Please also include any changes that have
occurred to benefits/accruals during the past five years.
Response:
Employee benefits at Falls Water Co., Inc. include:
Paid Vacation
Paid Sick Time
Flex Savings Accounts
Health Insurance
Vision Insurance
Dental Insurance
401(k) with Company Match up to 4%
Field Personnel receive a clothing allowance
No changes have been made in the past five years to benefits/accruals.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 9
REQUEST NO. 9: Please provide the depreciable life for all assets in Account 334 -
Meters, as well as all documentation and justification for how that length of life was
determined.
Response:
FLS-W-20-03 IPUC DR 9 Attachment 1 is an Excel file, “Request No 9.xls”. The file has
all the individual meters listed with the individual unit depreciation. The life of the water
meters historically has been determined by the warranty of the unit. Prior to June 2011,
all meters installed were Sensus SR2 meters. The manufacturer’s warranty was a 10-
year warranty. The depreciable life of these meters was set at 10-year straight-line.
The Company made the decision in June of 2011 to begin using Sensus IPERL meters.
The decision was made because of the better accuracy of the IPERL meter over the
SR2 model. The IPERL has a 20-year battery life and a 20-year warranty, full
replacement value for the first 10 years and a declining replacement value for the
remaining 10-years. The meters will generally last a bit longer than the warranty so the
depreciable life for the IPERL meters was set at 25-year straight-line.
On the Excel spreadsheet, a variety of straight-line values are shown. The reason for
the variation is due to the adjustment made to value the assets to the net book value of
the asset as of the date that Northwest Natural Water purchased Falls Water Co., Inc.
The adjusted straight-line life of the asset was calculated by dividing net book value as
of 9/14/2018 by the value of the monthly depreciation value for that unit, then dividing
the result by 12 months to determine the years of straight-line asset life carried to two
decimal places.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 11
REQUEST NO. 11: Please provide the source of the "Idaho Falls wage at years of service
by employee" data used in the "Payroll 2020" tab of the 2020 Rate Case Exhibits.
Response:
The City of Idaho Falls salary schedule can be found on line at:
https://www.idahofallsidaho.gov/DocumentCenter/View/7626/Salary-Chart-2019-PDF
The employee class titles used from the City of Idaho Falls Job Descriptions page
(https://www.idahofallsidaho.gov/189/Job-Descriptions) are:
Office Assistant I – Water
Water Laborer
Water Distribution Operator
Water Supply Operator
Water Service Operator
Water System Equipment Operator
Water Supply Foreman
Water Distribution Foreman
Lead Water Supply Operator
Water Lead Distribution Operator
Water Superintendent
The job descriptions list the pay grade to be used on the salary schedule.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 13
REQUEST NO. 13: Please provide copies of the Company's insurance policy coverage
and any invoices or receipts supporting the Company's insurance expense for 2019 and
pro forma Insurance Expense Charge from NWN.
Response:
Please refer to ‘FLS-W-20-03 IPUC DR 13 Attachment 1’ for a summary of the
Company’s insurance policy coverage and insurance expense for 2019, including the
allocated insurance charge from NW Natural. Please refer to ‘FLS-W-20-03 IPUC DR
13 Attachment 2’ for a copy of the Company’s ‘Certificate of Insurance’ to evidence the
company’s insurance policy coverage and expense.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 15
REQUEST NO. 15: Please provide the invoice and receipt for the $3 charge per
connection IDWH Fee paid to the Idaho Department of Environmental Quality for 2019.
Response:
Please see FLS-2-20-03 IPUC DR 15 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 14
REQUEST NO. 14: Does the Company expect to have any rate case expense for this
case?
Response:
The Company does not expect to have any external rate case expense for this case.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 20
REQUEST NO. 20: Please provide a copy of the Company's federal and state income
taxes for 2019.
Response:
The 2019 federal and state income tax returns for Falls Water Company (FWC) are not
expected to be filed with the respective taxing authorities until October 15, 2020. These
income tax returns have not yet been prepared. For your reference, we are sharing our
best estimate of the 2019 taxable income calculation for FWC (see the figure below).
This calculation was originally prepared in January 2020 and reflects the anticipated
2019 income tax reporting.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 16
REQUEST NO. 16: Please provide an itemized list of the services and costs provided
by NW Natural Water as shown in Exhibit 2, Column D. Please provide the calculations
of shared services with NW Natural Water in Excel format with formulas intact. Please
include a description of the Massachusetts method and why it was chosen.
Response:
Please refer to FLS-W-20-03 IPUC DR 16 – Attachment 1 for the itemized list of
services and costs provided by NW Natural Water that result in the $79,225 of costs to
be allocated to Falls Water as show in Exhibit 2, Column D.
The Massachusetts Method is the allocation process that has been selected by NW
Natural Water and its affiliates to allocate costs and to follow the National Association of
Regulatory Utility Commissioners (NARUC) Guidelines for Cost Allocations and Affiliate
Transactions. Consistent with the NARUC guidelines, for costs that cannot be directly
assigned, the Company should allocate costs based on the function or driver of the cost
and ensure that unauthorized subsidization of regulated or unregulated activities does
not occur. The general allocator is based on the Massachusetts Formula, which is a
generally accepted allocation formula used by many utilities. The Massachusetts
Formula uses an average of plant, revenues, and employee headcount for the
preceding year ended December 31st to allocate the indirect costs to affiliates. Costs
incurred by NW Natural Water or its affiliates that directly relate to an affiliate will be
directly assigned to that affiliate, and only the remaining unassigned expenses will be
allocated to the affiliates using the general corporate allocation methodology of the
Massachusetts method.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 17
REQUEST NO. 17: Please describe the "non-recurring non-utility income" removed
from net income in Exhibit 2, Column B.
Response:
Please see FLS-W-20-03 IPUC DR 17 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 19
REQUEST NO. 19: Please explain the Company's proposed $15,872 increase in
property taxes in Exhibit 2, Column E.
Response:
The year over year change in property taxes tends to bear a strong relationship to
changes in plant balance investments. The forecast for property taxes begins by
determining the ratio of current property tax to plant. This ratio is then applied to
forecasted increases in plant to arrive at forecasted property taxes.
The figure below provides the supporting calculation for the $15,872 increase in
property taxes and includes references to the source of the underlying information used.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 24
REQUEST NO. 24: Please provide a list of "out-of-period adjustments"and
"extraordinary items" for the years 2017 - 2020 to date.
Response:
The out-of-period adjustments found for the period requested were adjustments made
to asset and depreciation accounts as of the date Falls Water was purchased by
Northwest Natural Water. The entries were made to show the net book value of the
assets as of the date of purchase, September 14, 2018.
Extraordinary items occurring during the period include:
Purchase of Falls Water Co., Inc by Northwest Natural Water on September 14,
2018.
Sale of 12-inch water main to the City of Idaho Falls, Idaho on April 6, 2020.
System wide pressure loss on April 20, 2020.
Purchase of Taylor Mountain Water and Sewer District’s water business assets
on August 3, 2020.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 21
REQUEST NO. 21: Please explain the Company's provisions for deferred federal and
state income taxes. Please provide any associated schedules, analyses, or descriptions
of the Company's deferred income taxes.
Response:
Falls Water Company (FWC) does not currently have any federal or state accumulated
deferred income tax (ADIT) balances associated with regulatory rate accounting.
ADIT generally represents the cumulative difference between total income tax expense
and income taxes paid (total income tax expense = current income taxes + deferred
income taxes). We would generally expect that utility rates be designed in a general
rate case to allow for recovery of total utility income tax expense, both current and
deferred. Unfortunately, this has not historically been the case for FWC.
The figure below demonstrates that FWC was only allowed an income tax recovery of
19 percent in its last Idaho general rate case (2012). This was reasonable for the
estimate of income taxes paid but it did not contemplate a recovery of deferred income
taxes. In other words, ADIT has not been recovered in rate making.
FLS-W-20-03 IPUC DR 21
NWN Response
Page 2 of 3
In order for ADIT to be recovered in rate making, income tax expense in the
determination of revenue requirement must be determined using the full statutory rates
as in effect at the time. In 2012, this would have resulted in income tax expense of
$70,618 in ratemaking, versus the $30,659 actually allowed, to arrive at the same
approved return on equity of $130,164. The figure below demonstrates the proforma
calculation of income tax expense of $70,618 that would have applied to the approved
return on equity of $130,164 if income tax expense had been determined using the full
applicable rates in effect in 2012.
FLS-W-20-03 IPUC DR 21
NWN Response
Page 3 of 3
FWC does have ADIT balances in its books and records but those balances were not
previously recovered in utility rates. At the end of 2019 a net deferred income tax asset
balance of $234 thousand was recorded.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 22
REQUEST NO.22: Please describe how all overheads (including but not limited to
materials, supplies, vehicles, etc.) are allocated among plant and expense accounts.
Response:
The Company has not allocated overheads unless capitalizing labor and materials for
repairs and projects done by its employees.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 23
REQUEST NO. 23: Please provide a list of any events in 2019, such as unplanned
outages, storm damage or use of a diesel generator, that required repairs and/or
increased expenses.
Response:
In 2019, no events occurred that resulted in increased repair costs and/or increased
expenses.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 31
REQUEST NO. 31: Please provide the Company's practice for determining uncollectible
accounts and its policy for customer account deposits and terminations.
Response:
The Company considers an account uncollectible when a customer has moved
out of our service area and an outstanding balance remains on the books for three
months. The former customer is contacted by phone if the balance has not been paid
within two months of leaving our service area and is notified that an outstanding balance
is owed. The customer is given an opportunity to pay the balance or make a payment
arrangement. If the customer disputes the balance owed, we investigate the situation
and inform the customer of the findings. If a mistake was made on the Company’s part,
an adjustment is made. Otherwise the customer is asked to remit payment. The
customer is told that the past due account will be turned over to a collection agency in
the next month if payment is not received.
A voice message is left for the customer if possible when our employee cannot
speak directly to the former customer. They are asked to contact us about an unpaid
balance on their account.
If it is not possible to contact the former customer by phone and no other contact
information is available, the unpaid balance of the account is considered uncollectible
three months after the final billing goes out. The unpaid balance is turned over to a
collection agency three months after the final billing.
The Company does not require customer account deposits at this time.
The Company follows the IPUC’s Customer Relations Rules for termination of a
customer account for non-payment.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 25
REQUEST NO. 25: Please list any prepaid items for 2018 and 2019 showing amounts
posted, vendor names, explanations, and accounts to which these items were booked.
Please include within your response any significant changes to prepaid items occurring
or planned to occur in 2019 and 2020.
Response:
Prepaid items in Account 162.3 – Prepaid Insurance were posted December 31,
2019 for General Liability Insurance, Umbrella Insurance, Auto Insurance, and Workers
Compensation Insurance in the amount of $51,217.45. The Company has been under
NW Natural’s insurance policies since November 1, 2019. NW Natural provided the
prepaid insurance costs which are booked in the Prepaid Insurance account. The
original entry was booked as a debit to 162.3 – Prepaid Insurance of $51,217.45 and a
credit to 233.1 – NWN Water Intercompany Acct Pay of $51,217.45. Each month in
2020, $4,268.12 (1/12 of the total) has been moved by debiting Account 656 –
Insurance Expense and crediting Account 162.3 – Prepaid Insurance to recognize the
monthly insurance expense.
Prepaid Workers Compensation Insurance was posted to Account 162.2 –
Prepaid Workers Comp Insurance on November 11, 2018 in the amount of $1,561.80.
In October 2018, the amount had been incorrectly posted to Account 656.1 Workers
Compensation Ins when the policy renewal payment was posted. The policy was with
Advantage Workers Compensation Insurance Co. The prepaid balance of $1,561.80
was applied on October 1, 2019, to Account 241.6 – Workers Compensation Insurance
Liability to offset the September 2019 payroll workers compensation insurance liability.
No additional prepaid items are planned for 2019. In late 2020, the Company is
upgrading its billing software and SCADA software. It will also be acquiring notification
software to notify customers of outages and emergency situations. Currently, the
annual costs of these software applications have not been finalized.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 27
REQUEST NO. 27: Please provide a list of all contractors used in 2017, 2018, and 2019.
Please include with this response the contract amount, project name, project location, and
completion date.
Response:
Please see FLS-W-20-03 IPUC DR 27 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 30
REQUEST NO. 30: Please list all the Company's long-term debt issuances. Please
include: dates of issuance and expiration, amounts, premiums or discounts, interest
rates, dates of pre-payment, and payment schedules for each issuance.
Response:
Please see FLS-W-20-03 IPUC DR 30 Attachment 1 for the requested list. Please see
FLS-W-20-03 IPUC DR 30 Attachments 2 and 3 for a copy of the payment schedule for
each issuance.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 36
REQUEST NO. 36: Please explain why the Company is proposing a larger 38.89%
increase to its commodity charge than the 5.63% to its base charge.
Response:
In past rate cases, the Company has structured its request for revenues so that base
charges make up about 65% of total requested revenues and 35% of revenue is based
on commodity charges. In Order 32663 Attachment 2, the Commission-approved rate
design provides as a percentage of gross revenue a ratio of 67% minimum charge and
33% commodity charge.
In preparing the proposed rates for this rate case, the Company used the prior rate
design ratio as a guide. The ratio of the proposed rates in this case is 64.4% base and
35.6% commodity. The result was an increase in the commodity portion of 38.89%
versus a 5.63% increase in the base fee.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 32
REQUEST NO .32: Please provide a current hydraulic model of the Company's water
system.
Response:
A digital file will be provided of the latest hydraulic model of Falls Water’s system –
“FWC_2020_07_16.net”. It was created in EPANet version 2.0, which is a free
download at https://www.epa.gov/water-research/epanet.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 34
REQUEST NO. 34: Please provide a copy of the Company's policy for water main
extensions.
Response:
The Company’s policy for water main extensions is found in Appendix A of the 2010
General Tariff file, provided with this response as FLS-W-20-03 IPUC DR 34 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 35
REQUEST NO. 35: Please provide the following for each meter size for each month
from January 2017 through December 2019
a. Number of Billed Customer Charges
b. Gallons of water provided to customers at no charge as part of the Minimum Charge
c. Gallons sold to customers in excess of the maximum gallons allowed in the Minimum
Charge.
Response:
Please see FLS-W-20-03 IPUC DR 35 Attachment 1.
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FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 37
REQUEST NO. 37: Please confirm that all projects listed on Exhibit 1 are complete.
Response:
Please refer to the response to FLS-W-20-03 IPUC DR 5 as it confirms the status of the
projects listed in Exhibit 1. All projects are in service at this time. Final costs for the
project in Column B are incomplete because final invoices from the contractor have not
been received.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 38
REQUEST NO. 38: Column Q of the "Avg Mnthly Bill - Current Rates" tab of the 2020
Rate Case Exhibits shows the average monthly bill for each customer type (Residential,
Commercial, and Multi Family) and meter size. For some customer types, meter sizes,
and months, the average bill is smaller than the monthly basic charge. Please explain
this discrepancy in the following instances:
a. December: Residential 5/8" and 3/4" Meters
b. January through April, November and December: Residential 1" Meters
c. January through April: Commercial 2" Meters.
Response:
During the review of the discrepancies, an error in the calculation of the 2019 average
monthly billings was found. The “Avg Mnthly Bill – Current Rates” tab of the 2020 Rate
Case Exhibits used the actual revenues from 2019 and used total connections as of
December 31, 2019 to calculate the average monthly billings.
Please refer to FLS-W-20-03 IPUC DR 38 Attachment 1, an Excel file “Revised 2019
Average Monthly Bill per Active Customer,” to see the corrected average monthly billing
per active customer for 2019. Note that December: Residential 5/8” and ¾” Meters still
show an average less than the base charge. This is the result of a billing adjustment
made in December 2019 for a billing error of $6,881.04 to customer account 3.1369.01
in November 2019. The customer account’s usage was not corrected prior to the
billings being sent in November 2019 and the error was not found until December 2019.
Item b and item c discrepancies are the result of using the higher December 31, 2019
customer count instead of the actual monthly customer count as shown in “Revised
2019 Average Monthly Bill per Active Customer”. The discrepancies are corrected in
the revised file, FLS-W-20-03 IPUC DR 38 Attachment 1.
Rates & Regulatory Affairs
FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 40
REQUEST NO. 40: Please provide the Idaho Department of Water Resources unique
identifier (e.g. Well Tag/D-Tag Number) for each of the Company's wells.
Response:
Please see FLS-W-20-03 IPUC DR 40 Attachment 1.
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FLS-W-20-03
Falls Water Company Rate Case
Data Request Response
Request No.: FLS-W-20-03 IPUC DR 39
REQUEST NO. 39: For each of the Company's wells, please provide the quantity
(gallons) pumped for each month between January 2017 and December 2019.
Response:
Please see FLS-W-20-03 IPUC DR 39 Attachments 1 through 3 (2017, 2018, 2019).