U.S. Election Assistance Commission

633 3rd Street NW, Suite 200

Washington, DC 20001

U.S. Election Assistance Commission

Freedom of Information Act Annual Report

Fiscal Year 2020

Section I: Basic Information Regarding Report 

1. Interested parties with questions regarding this report may contact:

• Amanda Joiner, Associate Counsel 

633 3rd Street NW, Suite 200

Washington, DC 20001 

(202) 294-5227 

ajoiner@eac.gov 

2. The report is available via the following link: Election Assistance Commission Website - FOIA Reading Room

3. A copy of the Report in paper form can be obtained by contacting the EAC via phone, email, or mail. Contact information for 

the EAC is found at https://www.eac.gov/contactuseac 

Section II: Making a FOIA Request

1. Please direct FOIA requests to the following:

• Kevin Rayburn, General Counsel 

633 3rd Street NW, Suite 200
Washington, DC 20001 

(202) 740-6546 

krayburn@eac.gov

• Amanda Joiner, Associate Counsel 

633 3rd Street NW, Suite 200

Washington, DC 20001 

(202) 294-5227 

ajoiner@eac.gov

2. Please see below for a brief description of why some requests are not granted and an overview of certain general categories 

of the agency's records to which the FOIA exemptions apply: 

• Under the Freedom of Information Act, interested parties may request access to records held by the U.S. Election 

Assistance Commission. An important part of the EAC response process is ensuring that certain protected 

information is not improperly disclosed when records are provided. Such information is withheld if disclosure 

would harm an interest protected by one of the nine exemptions provided by FOIA. EAC records that are withheld 

from disclosure are typically protected by Exemptions 3, 4, 5, and 6, which encompass privacy concerns, predecisional and deliberative processes, and trade secrets. From a policy perspective, these exemptions are important 

to the mission of the EAC to encourage open discussions on matters of policy between subordinates and superiors, 

to protect against premature disclosure of proposed policies before formal adoption, and to protect against public 

confusion that might result from disclosure of reasons and rationales that were not ultimately grounds for an 

agency’s action. 

3. Below please find a link to agency FOIA regulations, including the agency's fee schedule. (NOTE: Agency FOIA 

Regulations were formerly listed at Section XI of the human-readable version of the Report).

• Election Assistance Commission Website - FOIA Guide

Section III: Acronyms, Definitions, and Exemptions
Agency Component Abbreviations

Component Component Name Abbreviation

EAC U.S. Election Assistance Commission

a. Administrative Appeal – a request to a federal agency asking that it review at a higher administrative level a FOIA determination 

made by the agency at the initial request level.

b. Average Number – the number obtained by dividing the sum of a group of numbers by the quantity of numbers in the group. For 

example, of 3, 7, and 14, the average number is 8. 

c. Backlog – the number of requests or administrative appeals that are pending at an agency at the end of the fiscal year that are 

beyond the statutory time period for a response. 

d. Component – for agencies that process requests on a decentralized basis, a "component" is an entity, also sometimes referred to as 

an Office, Division, Bureau, Center, or Directorate, within the agency that processes FOIA requests. The FOIA now requires that 

agencies include in their Annual FOIA Report data for both the agency overall and for each principal component of the agency. 

e. Consultation – the procedure whereby the agency responding to a FOIA request first forwards a record to another agency or 

component within the same agency for its review because that other agency has an interest in the document. Once the agency in

receipt of the consultation finishes its review of the record, it responds back to the agency or component within the same agency 

that forwarded it. That agency, in turn, will then respond to the FOIA requester. 

f. Exemption 3 Statute – a federal statute that exempts information from disclosure and which the agency relies on to withhold 

information under subsection (b)(3) of the FOIA.

g. FOIA Request – a FOIA request is generally a request to a federal agency for access to records concerning another person (i.e., a

"thirdparty" request), or concerning an organization, or a particular topic of interest. FOIA requests also include requests made by 

requesters seeking records concerning themselves (i.e., "first-party" requests) when those requesters are not subject to the Privacy 

Act, such as non U.S. citizens. Moreover, because all first-party requesters should be afforded the benefit of both the access 

provisions of the FOIA as well as those of the Privacy Act, FOIA requests also include any first-party requests where an agency 

determines that it must search beyond its Privacy Act "systems of records" or where a Privacy Act exemption applies, and the 

agency looks to FOIA to afford the greatest possible access. All requests which require the agency to utilize the FOIA in

responding to the requester are included in this Report. Additionally, a FOIA request includes records referred to the agency for 
processing and direct response to the requester. It does not, however, include records for which the agency has received a 

consultation from another agency. (Consultations are reported separately in Section XII of this Report.)

h. Full Grant – an agency decision to disclose all records in full in response to a FOIA request. 

i. Full Denial – an agency decision not to release any records in response to a FOIA request because the records are exempt in their 

entireties under one or more of the FOIA exemptions, or because of a procedural reason, such as when no records could be located. 

j. Median Number – the middle, not average, number. For example, of 3, 7, and 14, the median number is 7. 

k. Multi-Track Processing – a system in which simple requests requiring relatively minimal review are placed in one processing track 

and more voluminous and complex requests are placed in one or more other tracks. Requests granted expedited processing are 

placed in yet another track. Requests in each track are processed on a first in/first out basis.

i. Expedited Processing – an agency will process a FOIA request on an expedited basis when a requester satisfies the

requirements for expedited processing as set forth in the statute and in agency regulations. 

ii. ii. Simple Request – a FOIA request that an agency using multi-track processing places in its fastest (nonexpedited) track 

based on the low volume and/or simplicity of the records requested.

iii. iii. Complex Request – a FOIA request that an agency using multi-track processing places in a slower track based on the high 

volume and/or complexity of the records requested. 

l. Partial Grant/Partial Denial – in response to a FOIA request, an agency decision to disclose portions of the records and to withhold 

other portions that are exempt under the FOIA, or to otherwise deny a portion of the request for a procedural reason. 

m. Pending Request or Pending Administrative Appeal – a request or administrative appeal for which an agency has not taken final 

action in all respects.

n. Perfected Request – a request for records which reasonably describes such records and is made in accordance with published rules 

stating the time, place, fees (if any) and procedures to be followed. 

o. Processed Request or Processed Administrative Appeal – a request or administrative appeal for which an agency has taken final 

action in all respects.

p. Range in Number of Days – the lowest and highest number of days to process requests or administrative appeals.

q. Time Limits – the time period in the statute for an agency to respond to a FOIA request (ordinarily twenty working days from 

receipt of a perfected FOIA request).

Descriptions of the nine FOIA exemptions:
a. Exemption 1: classified national defense and foreign relations information

b. Exemption 2: information that is related solely to the internal personnel rules and practices of an agency

c. Exemption 3: information that is prohibited from disclosure by another federal law

d. Exemption 4: trade secrets and other confidential business information 

e. Exemption 5: inter-agency or intra-agency communications that are protected by legal privileges 

f. Exemption 6: information involving matters of personal privacy

g. Exemption 7: records or information compiled for law enforcement purposes, to the extent that the production of those records 

(A) could reasonably be expected to interfere with enforcement proceedings, (B) would deprive a person of a right to a fair trial or 

an impartial adjudication, (C) could reasonably be expected to constitute an unwarranted invasion of personal privacy, (D) could 

reasonably be expected to disclose the identity of a confidential source, (E) would disclose techniques and procedures for law 

enforcement investigations or prosecutions, or would disclose guidelines for law enforcement investigations or prosecutions, or 

(F) could reasonably be expected to endanger the life or physical safety of any individual 

h. Exemption 8: information relating to the supervision of financial institutions

i. Exemption 9: geological information on wells
3. Agency Component Abbreviations

Component 

Abbreviation Component Name

EAC U.S. Election Assistance Commission

IV. Exemption 3 Statutes

Statute

Type of 

Information 

Withheld

Case Citation Agency / 

Component

Number of 

Times

Relied 

upon

by Agency 

/ 

Component

Total 

Number 

of

Times 

Relied 

upon

by 

Agency 

Overall

N/A N/A N/A EAC 0 0

V.A. FOIA REQUESTS -- RECEIVED, PROCESSED AND PENDING FOIA REQUESTS

Agency / Component

Number of 

Requests

Pending as of 

Start

of Fiscal Year

Number of

Requests 

Received

in Fiscal Year

Number of

Requests 

Processed

in Fiscal Year

Number of 

Requests

Pending as of 

End

of Fiscal Year

EAC 11 49 21 39

AGENCY OVERALL 11 49 21 39
After reviewing its database, EAC has adjusted the number of requests pending as of the start 

of the Fiscal Year.

V.B.(1). DISPOSITION OF FOIA REQUESTS -- ALL PROCESSED REQUESTS

Agency / 

Component

Number 

of Full 

Grants

Number 

of 

Partial 

Grants / 

Partial 

Denials

Number of 

Full 

Denials 

Based on 

Exemptions

Number of Full Denials Based on Reasons Other than Exemptions

No 

Records

All 

Records 

Referred to 

Another 

Component 

or Agency

Request 

Withdrawn

FeeRelated 

Reason

Records 

not 

Reasonably 

Described

Improper 

FOIA 

Request 

for Other 

Reason

Not 

Agency 

Record

Duplicate 

Request

Other 

*Explain 

in Chart 

Below

TOTAL

EAC 8 2 0 11 0 0 0 0 0 0 0 0 21

AGENCY 

OVERALL 8 2 0 11 0 0 0 0 0 0 0 0 21

V.B.(2). DISPOSITION OF FOIA REQUESTS -- "OTHER" REASONS FOR "FULL DENIALS BASED ON REASONS OTHER THAN 

EXEMPTIONS"

Agency / 

Component

Description of "Other" Reasons for Denials 

from Chart B(1)

Number 

of Times 

"Other" 

Reason 

Was 

Relied 

Upon

TOTAL

EAC N/A 0 0

AGENCY 

OVERALL 0
V.B.(3). DISPOSITION OF FOIA REQUESTS -- NUMBER OF TIMES EXEMPTIONS APPLIED

Agency / 

Component

Ex. 

1

Ex. 

2

Ex. 

3

Ex. 

4

Ex. 

5

Ex. 

6

Ex. 

7(A)

Ex. 

7(B)

Ex. 

7(C)

Ex. 

7(D)

Ex. 

7(E)

Ex. 

7(F)

Ex. 

8

Ex. 

9

EAC 0 0 0 1 0 1 0 0 0 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 1 0 1 0 0 0 0 0 0 0 0

VI.A. ADMINISTRATIVE APPEALS OF INITIAL DETERMINATIONS OF FOIA REQUESTS -- RECEIVED, PROCESSED, AND 

PENDING ADMINISTRATIVE APPEALS

Agency / 

Component

Number of 

Appeals

Pending as of 

Start

of Fiscal Year

Number of

Appeals 

Received

in Fiscal Year

Number of

Appeals 

Processed

in Fiscal Year

Number of 

Appeals

Pending as of 

End

of Fiscal Year

EAC 1 0 0 1

AGENCY 

OVERALL 1 0 0 1
VI.B. DISPOSITION OF ADMINISTRATIVE APPEALS -- ALL PROCESSED APPEALS

Agency / 

Component

Number 

Affirmed on 

Appeal

Number Partially 

Affirmed & 

Partially 

Reversed/Remanded 

on Appeal

Number Completely 

Reversed/Remanded 

on Appeal

Number of 

Appeals 

Closed for 

Other 

Reasons

TOTAL

EAC 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0

VI.C.(1). REASONS FOR DENIAL ON APPEAL -- NUMBER OF TIMES EXEMPTIONS APPLIED

Agency / 

Component

Ex. 

1

Ex. 

2

Ex. 

3

Ex. 

4

Ex. 

5

Ex. 

6

Ex. 

7(A)

Ex. 

7(B)

Ex. 

7(C)

Ex. 

7(D)

Ex. 

7(E)

Ex. 

7(F)

Ex. 

8

Ex. 

9

EAC 0 0 0 0 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0 0 0 0 0 0 0 0 0 0

VI.C.(2). REASONS FOR DENIAL ON APPEAL -- REASONS OTHER THAN EXEMPTIONS
Agency / 

Component

No 

Records

Records 

Referred 

at Initial 

Request 

Level

Request 

Withdrawn

FeeRelated 

Reason

Records 

not 

Reasonably 

Described

Improper 

Request 

for Other 

Reasons

Not 

Agency 

Record

Duplicate 

Request 

or 

Appeal

Request 

in 

Litigation

Appeal 

Based 

Solely on 

Denial of 

Request 

for 

Expedited 

Processing

Other 

*Explain 

in chart 

below

EAC 0 0 0 0 0 0 0 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 0 0 0 0 0 0 0

VI.C.(3). REASONS FOR DENIAL ON APPEAL -- "OTHER" REASONS

Agency / 

Component

Description of "Other" Reasons for Denial on 

Appeal from Chart C(2)

Number of 

Times 

"Other" 

Reason 

Was 

Relied 

Upon

TOTAL

EAC N/A 0 0

AGENCY 

OVERALL 0

VI.C.(4). RESPONSE TIME FOR ADMINISTRATIVE APPEALS
Agency / 

Component

Median Number 

of Days

Average 

Number of Days

Lowest Number 

of Days

Highest Number 

of Days

EAC N/A N/A N/A N/A

AGENCY 

OVERALL N/A N/A N/A N/A

VI.C.(5). TEN OLDEST PENDING ADMINISTRATIVE APPEALS

Agency / 

Component

10th 

Oldest 

Appeal

9th 8th 7th 6th 5th 4th 3rd 2nd Oldest 

Appeal

EAC

Date of 

Appeal N/A N/A N/A N/A N/A N/A N/A N/A N/A

2019-

01-29

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 0 416

AGENCY 

OVERALL

Date of 

Appeal N/A N/A N/A N/A N/A N/A N/A N/A N/A

2019-

01-29

Number 

of Days 

Pending 0 0 0 0 0 0 0 0 0 416
VII.A. FOIA REQUESTS -- RESPONSE TIME FOR ALL PROCESSED PERFECTED REQUESTS

Agency / 

Component

SIMPLE COMPLEX EXPEDITED PROCESSING

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

EAC 14 46 2 152 135 139 9 248 112 98 47 134

AGENCY 

OVERALL 14 46 2 152 135 139 9 248 112 98 47 134

VII.B. PROCESSED REQUESTS -- RESPONSE TIME FOR PERFECTED REQUESTS IN WHICH INFORMATION WAS GRANTED

Agency / 

Component

SIMPLE COMPLEX EXPEDITED PROCESSING

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

Median 

Number 

of Days

Average 

Number 

of Days

Lowest 

Number 

of Days

Highest 

Number 

of Days

EAC 24 43 2 152 132 125 106 137 80 80 47 112

AGENCY 

OVERALL 24 43 2 152 132 125 106 137 80 80 47 112

VII.C. PROCESSED SIMPLE REQUESTS -- RESPONSE TIME IN DAY INCREMENTS
Agency / 

Component

<1-

20

Days

21-

40

Days

41-

60

Days

61-

80

Days

81-

100 

Days

101-

120 

Days

121-

140 

Days

141-

160 

Days

161-

180 

Days

181-

200 

Days

201-

300 

Days

301-

400 

Days

401+

Days TOTAL

EAC 7 0 2 0 0 1 0 2 0 0 0 0 0 12

AGENCY 

OVERALL 7 0 2 0 0 1 0 2 0 0 0 0 0 12

VII.C. PROCESSED COMPLEX REQUESTS -- RESPONSE TIME IN DAY INCREMENTS

Agency / 

Component

<1-

20

Days

21-

40

Days

41-

60

Days

61-

80

Days

81-

100 

Days

101-

120 

Days

121-

140 

Days

141-

160 

Days

161-

180 

Days

181-

200 

Days

201-

300 

Days

301-

400 

Days

401+

Days TOTAL

EAC 1 0 0 0 0 1 2 0 0 0 2 0 0 6

AGENCY 

OVERALL 1 0 0 0 0 1 2 0 0 0 2 0 0 6

VII.C. PROCESSED REQUESTS GRANTED EXPEDITED PROCESSING -- RESPONSE TIME IN DAY INCREMENTS

Agency / 

Component

<1-

20

Days

21-

40

Days

41-

60

Days

61-

80

Days

81-

100 

Days

101-

120 

Days

121-

140 

Days

141-

160 

Days

161-

180 

Days

181-

200 

Days

201-

300 

Days

301-

400 

Days

401+

Days TOTAL

EAC 0 0 1 0 0 1 1 0 0 0 0 0 0 3
AGENCY 

OVERALL 0 0 1 0 0 1 1 0 0 0 0 0 0 3

VII.D. PENDING REQUESTS -- ALL PENDING PERFECTED REQUESTS

Agency / 

Component

SIMPLE COMPLEX EXPEDITED PROCESSING

Number 

Pending

Median 

Number 

of Days

Average 

Number 

of Days

Number 

Pending

Median 

Number 

of Days

Average 

Number 

of Days

Number 

Pending

Median 

Number 

of Days

Average 

Number 

of Days

EAC 16 113 150 17 183 203 6 36 37

AGENCY 

OVERALL 16 113 150 17 183 203 6 36 37

VII.E. PENDING REQUESTS -- TEN OLDEST PENDING PERFECTED REQUESTS

Agency / 

Component

10th 

Oldest 

Request

9th 8th 7th 6th 5th 4th 3rd 2nd Oldest 

Request

EAC

Date of 

Receipt

2019-

10-18

2019-

09-09

2019-

09-09

2019-

08-08

2019-

07-29

2019-

06-24

2019-

05-21

2019-

05-20

2019-

05-20

2019-

01-31

Number 

of Days 

Pending 236 257 257 286 294 318 341 341 341 418
AGENCY 

OVERALL

Date of 

Receipt

2019-

10-18

2019-

09-09

2019-

09-09

2019-

08-08

2019-

07-29

2019-

06-24

2019-

05-21

2019-

05-20

2019-

05-20

2019-

01-31

Number 

of Days 

Pending 236 257 257 286 294 318 341 341 341 418

VIII.A. REQUESTS FOR EXPEDITED PROCESSING

Agency / 

Component

Number 

Granted

Number 

Denied

Median 

Number of 

Days to 

Adjudicate

Average 

Number of 

Days to 

Adjudicate

Number 

Adjudicated 

Within Ten 

Calendar 

Days

EAC 9 0 123 123 0

AGENCY 

OVERALL 9 0 123 123 0 

VIII.B. Requests for Fee Waiver

Agency / 

Component

Number 

Granted

Number 

Denied

Median 

Number of 

Days to 

Adjudicate

Average 

Number of 

Days to 

Adjudicate
EAC 0 0 N/A N/A

AGENCY 

OVERALL 0 0 N/A N/A

IX. FOIA Personnel and Costs

Agency / 

Component

PERSONNEL COSTS

Number of 

"Full-Time 

FOIA 

Employees"

Number of 

"Equivalent 

Full-Time 

FOIA 

Employees"

Total 

Number 

of "FullTime 

FOIA 

Staff"

Processing 

Costs

LitigationRelated 

Costs

Total 

Costs

EAC 0 1.00 1.00 25000.00 0.00 25000.00

AGENCY 

OVERALL 0 1.00 1.00 25000.00 0.00 25000.00

X. Fees Collected for Processing Requests
Agency / 

Component

Total Amount 

of Fees 

Collected

Percentage of 

Total Costs

EAC 0.00 0.0000

AGENCY 

OVERALL 0.00 0.0000

XI.A. Number of Times Subsection (C) Used

Agency / Component Number of Times Subsection 

Used

EAC 0

AGENCY 

OVERALL 0 

XI.B. Number of Subsection (A)(2) Postings

Agency / 

Component Number of 

Records 

Number of 

Records 

Posted by 
Posted by the 

FOIA Office

Program 

Offices

EAC 74 0

AGENCY 

OVERALL 74 0 

XII.A. Backlogs of FOIA Requests and Administrative Appeals

Agency / 

Component

Number of 

Backlogged 

Requests as of 

End of Fiscal 

Year

Number of 

Backlogged 

Appeals as of 

End of Fiscal 

Year

EAC 10 0

AGENCY 

OVERALL 10 0 

XII.B. CONSULTATIONS ON FOIA REQUESTS -- RECEIVED, PROCESSED, AND PENDING CONSULTATIONS

Agency / 

Component

Number of 

Consultations 

Received from 

Other Agencies 

that were 

Number of

Consultations 

Received from 

Other Agencies 

Number of 

Consultations 

Received from 

Other Agencies 

that were 

Number of 

Consultations 

Received from 

Other Agencies 

that were 
Pending at the 

Agency as of 

Start

of the Fiscal 

Year

During the 

Fiscal Year

Processed by the 

Agency During 

the Fiscal Year

Pending at the 

Agency as of 

End

of the Fiscal 

Year

EAC 0 1 1 0

AGENCY 

OVERALL 0 1 1 0

XII.C. CONSULTATIONS ON FOIA REQUESTS -- TEN OLDEST CONSULTATIONS RECEIVED FROM OTHER AGENCIES AND 

PENDING AT THE AGENCY

Agency / 

Component

10th Oldest 

Consultation 9th 8th 7th 6th 5th 4th 3rd 2nd Oldest Consultation

EAC

Date N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Number 

of Days 0 0 0 0 0 0 0 0 0 0 

AGENCY 

OVERALL

Date N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A

Number 

of Days 0 0 0 0 0 0 0 0 0 0 

XII.D.(1). COMPARISON OF NUMBERS OF REQUESTS FROM PREVIOUS AND CURRENT ANNUAL REPORT -- REQUESTS 

RECEIVED AND PROCESSED
Agency / 

Component

NUMBER OF REQUESTS 

RECEIVED

NUMBER OF REQUESTS 

PROCESSED

Number 

Received 

During Fiscal 

Year from Last 

Year's Annual 

Report

Number 

Received 

During Fiscal 

Year from 

Current Annual 

Report

Number 

Processed 

During Fiscal 

Year from Last 

Year's Annual 

Report

Number 

Processed 

During Fiscal 

Year from 

Current Annual 

Report

EAC 30 49 17 21

AGENCY 

OVERALL 30 49 17 21

XII.D.(2). COMPARISON OF NUMBERS OF REQUESTS FROM PREVIOUS AND CURRENT ANNUAL REPORT -- 

BACKLOGGED REQUESTS

Agency / 

Component

Number of 

Backlogged 

Requests as of 

End of the Fiscal 

Year from 

Previous Annual 

Report

Number of 

Backlogged 

Requests as of 

End of the Fiscal 

Year from 

Current Annual 

Report

EAC 5 10

AGENCY 

OVERALL 5 10
XII.E.(1). COMPARISON OF NUMBERS OF ADMINISTRATIVE APPEALS FROM PREVIOUS AND CURRENT ANNUAL 

REPORT -- APPEALS RECEIVED AND PROCESSED

Agency / 

Component

NUMBER OF APPEALS 

RECEIVED

NUMBER OF APPEALS 

PROCESSED

Number 

Received 

During Fiscal 

Year from Last 

Year's Annual 

Report

Number 

Received 

During Fiscal 

Year from 

Current Annual 

Report

Number 

Processed 

During Fiscal 

Year from Last 

Year's Annual 

Report

Number 

Processed 

During Fiscal 

Year from 

Current Annual 

Report

EAC 0 0 0 0

AGENCY 

OVERALL 0 0 0 0 

XII.E.(2). COMPARISON OF NUMBERS OF ADMINISTRATIVE APPEALS FROM PREVIOUS AND CURRENT ANNUAL 

REPORT -- BACKLOGGED APPEALS

Agency / 

Component

Number of 

Backlogged 

Appeals as of 

End of the Fiscal 

Year from 

Previous Annual 

Report

Number of 

Backlogged 

Appeals as of 

End of the Fiscal 

Year from 

Current Annual 

Report
EAC

10

AGENCY 

OVERALL 1 0