Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 

 

 

 

 

 

 

 

 

FEDERAL MARITIME COMMISSION

 

 

FINAL ANNUAL PERFORMANCE PLAN 

FOR FY 2009

February 2008 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 1

LIST OF ACRONYMS 

1984 Act Shipping Act of 1984 

ADR Alternative Dispute Resolution 

FMC/Commission Federal Maritime Commission 

FISMA Federal Information Security Management Act of 2002 

FSPA Foreign Shipping Practices Act of 1988 

FTE Full Time Equivalent Employee 

FY Fiscal Year 

GPEA Gov’t. Paperwork Elimination Act 

GPRA Gov’t. Performance and Results Act 

IT Information Technology 

NSA NVOCC Service Arrangement 

NVOCC Non-Vessel Operating Common Carrier 

OMB Office of Management and Budget 

OSRA Ocean Shipping Reform Act of 1998 

OTI Ocean Transportation Intermediary 

SBREFA Small Business Regulatory Fairness Act of 1996 

SC Service Contract 

Section 6(g) Section 6(g) of the Shipping Act of 1984 

Section 19 Section 19 of the Shipping Act of 1984 

SOP Standard Operating Procedure 

U.S. United States 

VOCC Vessel-Operating Common Carrier 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 2

INTRODUCTION

This document comprises the FMC’s Final Annual Performance Plan for FY 2009. As set forth in GPRA and 

general guidelines published by OMB, the Commission has prepared a single Performance Plan so as to present a 

comprehensive picture of performance across the agency. This plan is closely linked to the agency’s Strategic Plan. 

This plan differs from the FMC’s Initial Annual Performance Plan for FY 2009 submitted in September 2007. In 

this final plan, the FMC has developed performance measures and targets that are directly linked to the Outcome 

Goals set forth in the agency’s Strategic Plan. This final plan introduces measures that will evaluate the success 

over time of the Outcome Goals established in the FMC’s Strategic Plan, unlike the initial plan which was 

confined to annual performance goals encompassing particular, current objectives. It is envisioned that further and 

more comprehensive performance measures will be developed when the Strategic Plan is next updated. That 

update is scheduled to commence in February, 2008. 

For FY 2009, we have continued the modified approach for our annual planning first implemented with our 

Revised Annual Performance Plan for FY 2005. Agency performance goals are tied directly to Strategic Goals 

instead of our budget program activities. This has resulted in the development of performance goals better suited 

to the achievement of agency-wide objectives, as opposed to more narrowly focused goals tailored to the 

responsibilities of individual units. It also facilitates our aim of utilizing a more inclusive, collaborative approach 

in conducting our ongoing activities, which we believe both enhances decision-making and improves ultimate 

results. Addressing our performance goals in this fashion has enabled us to link planning, budgeting and 

performance more effectively. 

The Commission used its existing consultation process in developing this Plan. We continued our ad hoc meetings 

and visits with industry officials to discuss the state of U.S. ocean shipping and the FMC’s oversight 

responsibilities. In coordination with the various sectors of the maritime industry, we have held periodic briefings 

by industry experts designed to provide Commission staff with valuable information on industry services, 

operations, business practices, and regulatory concerns. The information and opinions we received via these 

various efforts have assisted us in developing our performance goals and implementing approaches. It is clear that 

those involved in the various sectors of U.S. ocean shipping understand the Commission=s major program 

activities and, at the same time, the Commission is cognizant of the views of all parties with whom it interacts. 

 

In line with OMB guidance, the Commission has reflected the resources needed to accomplish its various 

functions. We have provided FTE and funding figures for each Strategic Goal, which reflect what we believe will 

be required to accomplish the performance goals and “steady state” functions under each respective Strategic Goal. 

Accordingly, all Commission resources are accounted for in this Plan, i.e., the figures under each Strategic Goal, 

when summed, reflect the full FTE and funding levels of our FY 2009 budget. 

The Commission will post this Final Annual Performance Plan on its Internet website to ensure that it is readily 

accessible to interested parties, and will advise all employees to take the time to review it. Additionally, all 

employee performance plans are required to comport with the agency’s Strategic and Annual Performance Plans, 

and contain specific elements and standards with a clear explanation of what is expected of the employee in 

support of the agency achieving its goals. This process in turn has the effect of directly furthering the 

Administration’s initiative on strategic human capital management. Performance of managers and staff is 

evaluated in part on how they achieve the objectives in this plan. 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 3

FMC VISION AND MISSION

The FMC’s vision is: 

Fairness and Efficiency in U.S. Maritime Commerce. 

To achieve its vision, the FMC’s mission is to: 

• Develop and administer policies and regulations that foster a fair, efficient and secure 

maritime transportation system. 

• Protect U.S. maritime commerce from unfair foreign trade practices and marketdistorting activities. 

• Facilitate compliance with U.S. shipping statutes through outreach and oversight. 

• Assist in resolving disputes.

OSRA and the events of September 11, 2001, have significantly changed the manner in which the business of 

ocean shipping is being conducted. The industry continues to restructure its operations to adapt to dynamic 

economic conditions, emerging trends, and maritime security efforts. International trade remains dependent upon 

an efficient ocean transportation system. Therefore, it is imperative for the FMC to ensure that its oversight 

activities produce a competitive trading environment in U.S. ocean commerce that is in harmony with and 

responsive to international shipping practices, and permits fair and open commerce. We must focus our energies 

and efforts on this mission, and assure that the agency is organized and managed in a manner best suited to 

accomplish it with a minimum of government intervention and regulatory cost. Effective use of emerging 

information technologies will facilitate our efforts. Our actions also must encourage the development of a sound 

U.S.-flag liner fleet. Accordingly, the FMC has established the following five strategic goals to carry out its 

statutory mandates. 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 4

FMC STRATEGIC GOALS

1. Efficient Regulatory Process: Provide a timely, efficient and decisive regulatory process, 

including alternative dispute resolution, to enable all segments of the industry to operate 

more effectively, with a minimum of regulatory costs. 

2. Compliance: Promote efficiency and fairness in U.S. foreign waterborne commerce 

through various means, including outreach and monitoring, to protect the public and 

assist stakeholders in achieving compliance with ocean transportation statutes 

administered by the FMC.

3. Balanced Enforcement: Foster economic efficiencies, reliance on marketplace factors 

and maritime security by administering U.S. shipping statutes in a balanced and equitable 

manner to redress excessive anticompetitive actions and other unlawful activities. 

4. Technological Efficiencies: Employ technological enhancements to improve efficiency 

and to facilitate the exchange of information. 

5. Management Capabilities: Ensure the FMC has the appropriate organizational 

framework and management systems to carry out its statutory mandates. 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 5

LINKAGE BETWEEN MISSION STATEMENT 

AND STRATEGIC GOALS 

Our strategic goals address essential FMC statutory, programmatic, and management responsibilities. They were 

developed with a specific focus on accomplishing the basic purposes of our mission and attaining the competitive, 

nondiscriminatory shipping environment envisioned by the 1984 Act, as amended by OSRA. 

The primary intention of Strategic Goal 1 is to minimize regulatory costs by maintaining timely and decisive 

regulatory processes, and providing various dispute resolution services. This will render the FMC more effective 

in addressing discrimination or other actions that preclude industry efficiency, while reducing the costs of pursuing 

matters before the Commission. Decisive action and effective assistance in resolving informal complaints or 

disputes will help to remove uncertainties as to statutory interpretations or the application of FMC rules. Such 

uncertainties may impede operational efficiencies or technological changes, each of which can foster a more 

economical ocean shipping system. 

Our second strategic goal centers on achieving compliance with the substantive provisions of the shipping statutes 

the FMC administers, and protecting those involved in U.S. ocean commerce from unfair practices. We will 

address this goal particularly by interacting with all sectors of the industry, and by vigilant monitoring of ongoing 

commercial activities. Accomplishing this goal should minimize the unjust discrimination and undue preference or 

prejudice that precludes certain shipping interests from obtaining rates or service levels that can render their 

businesses more economic and efficient. Increasing industry compliance should enable stakeholders to concentrate 

on fair and legal means of enhancing operational efficiency, secure in the knowledge that competitors are not 

engaging in widespread illegal actions aimed at improving short-term profits. The agency’s focus on the 

qualifications of intermediaries operating in the U.S. trades will afford greater protection to our stakeholders and 

contribute to national maritime security. And cruise passengers also will be protected through the demonstration 

of financial responsibility by passenger vessel operators. 

Strategic Goal 3 is designed to foster economic efficiencies, assist maritime security initiatives, promote reliance 

on marketplace factors, and redress excessive anticompetitive practices harmful to international commerce. This is 

a direct link to our mission statement’s call for an efficient, secure, competitive, market-driven ocean 

transportation system. Our continuing efforts to address the actions of foreign governments that adversely affect 

U.S. interests and our foreign trade comport with that aspect of our mission aimed at creating an environment “free 

of unfair foreign maritime trade practices.” Our focus on commercial malpractices enhances our objective of 

limiting unlawful activities. 

We also have a specific strategic goal that focuses on making effective use of advancements in IT to improve the 

efficiency of our operations and enhance our exchange of information with external parties. Carrying out the 

agency’s mission in times of budgetary limitations dictates that we appropriately utilize all available resources. 

Dynamic changes continue to be made in this area, and the Commission intends to take advantage of any 

improvement that can enable it to perform its functions more effectively. We hope to improve our business 

operations so as to add efficiency to the Commission’s dissemination and receipt of information. We intend to 

perform the research and analysis necessary to identify the best options for implementing technical enhancements 

to facilitate our efforts to achieve our mission. 

Finally, our fifth strategic goal addresses Commission management and operations. In order to achieve the 

objectives of our mission, we must maintain effective processes that enhance efficiency, without serving as ends in 

themselves. It is essential that we manage for results, and that we effectively tie our budget needs to our 

performance. This strategic goal serves as the internal underpinning that enables us to accomplish the policy 

objectives set forth in our mission statement. This goal also ensures continuation of a comprehensive approach to 

the strategic management of our human capital. 

Achieving these mission-driven goals will enable us to address the external factors we face, while assuring an 

equitable and efficient administration of the shipping statutes under our jurisdiction. Our processes and procedures 

will be refined or updated as necessary. We are committed to accomplishing our strategic goals and the Outcome 

Goals related to them. Therefore, specific means have been identified to enable the FMC to achieve these goals in 

the most cost-efficient and least disruptive manner possible. 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 6

Strategic Goal No. 1: Efficient Regulatory Process Provide a timely, efficient and decisive regulatory process, including alternative dispute resolution, to enable all 

segments of the industry to operate more effectively, with a minimum of regulatory costs. 

43 FTEs and $8,500,000.00 will be required to accomplish this goal. 

A. 2009 Steady State Activities:

• Adjudication and resolution of complaints. 

• Adjudication and resolution of investigatory proceedings, including fact-findings and show 

cause proceedings. 

• Issuance of rules through the rulemaking process. 

• Commission decision-making activities through meetings (formal and notation) that comply 

with the Government in the Sunshine Act. 

• Public information and assistance processes such as press relations, responses to legislative 

and regulatory inquiries, and compliance with Freedom of Information Act and Privacy Act 

requirements. 

• Other regulatory processes, including activities such as appeals of delegated authority 

actions, policy issuances, and formal petition processes. 

• Providing timely legal counsel to the Commission in order to facilitate regulatory action that 

is consistent with statutory mandates, representing the Commission’s interest in matters 

before Congress and OMB. 

• Reviewing and refining Commission rules to determine their economic impact and ensure 

that they reflect the current industry environment, as well as meet the needs of the 

Commission’s regulatory mandate. 

• Compiling, organizing, and maintaining Commission records. 

• Monitor, review and modify, as necessary, Commission regulations to address changing 

trade conditions, industry practices or statutory modifications. 

B. Outcome Goals 

 Outcome Goal 1.1: Provide parties to proceedings with alternative means to resolve their disputes, 

including informal ADR, and encourage their use. 

Measure: Disputes resolved by Office of Consumer Affairs and Dispute Resolution Services 

 Target: 100 

Outcome Goal 1.2: Conduct hearings in an expeditious and equitable manner, so that litigants and 

the industry can adjust their behavior accordingly. 

Measure: Percentage of complaints or investigations completed within two years of filing or 

Commission initiation beginning with cases filed or initiated in FY 2007. 

Target: 60% 

Outcome Goal 1.3: Permit and encourage the use of electronic filings and other processes that 

result in less expense and timely resolution of disputes. 

Measure: Percentage of Active Electronic Docket Logs updated within 72 hours of receipt of 

key documents issued or filed in Commission proceedings. 

Target: 85% 

Outcome Goal 1.4: Update Commission rules as appropriate to adjust to changes in the regulatory 

and commercial environment. 

Measure: Number of rules pending in Unified Regulatory Agenda. 

Target: 2 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 7

Strategic Goal No. 2: Compliance

Promote efficiency and fairness in U.S. foreign waterborne commerce through various means, including outreach 

and monitoring, to protect the public and assist stakeholders in achieving compliance with ocean transportation 

statutes administered by the FMC.

31 FTEs and $5,388,000.00 will be required to accomplish this goal. 

A. 2009 Steady State Activities:

• Reviewing and maintaining a database of SCs between (also NSAs between NVOCCS) 

ocean common carriers and shippers, and using this database to guard against 

anticompetitive practices and other unfair prohibited activities under the 1984 Act. 

• Ensuring that common carriers’ rates and charges are accessible to the shipping public in 

private, electronically accessible systems. 

• Ensuring that OTIs maintain bonds that protect the shipping public from financial losses. 

• Providing formal and informal legal opinions and guidance to the Commission’s staff and 

the general public to ensure clarity and understanding of Commission rules and regulations. 

• Administering the Commission’s international affairs program. 

• Coordinate with other agencies regarding maritime security. 

• Reviewing operational and pricing agreements among ocean common carriers and marine 

terminals to ensure that they do not unduly restrict competition. 

• Issuing passenger vessel certificates evidencing financial responsibility of vessel owners or 

charterers to pay judgments for personal injury or death or to repay fares for the 

nonperformance of voyage or cruise. 

• Licensing OTIs to protect the public from unqualified, insolvent, or dishonest companies. 

• Responding to informal complaints and informal inquiries from Congress and the public 

relating to Commission responsibilities. 

• Acting as a liaison between the FMC and the public by responding and/or coordinating 

agency responses to public inquiries. 

• Maintaining a specialized maritime law library for agency and public use. 

• Conducting audit activity of regulated entities, including OTIs and VOCCs, to promote and 

ensure compliance with applicable statutes and Commission regulations. 

• Responding to inquiries and complaints from the regulated industry and shipping public. 

Providing information, assistance and forms necessary to comply with applicable statutes 

and Commission regulations including educational seminars. 

B. Outcome Goals 

 

Outcome Goal 2.1: Increase the rate of compliance under applicable U.S. shipping laws and 

regulations relating to tariffs, service contracts, unfair trade practices, antitrust immunity, 

discriminatory practices, carrier pricing and service, ocean transportation intermediary activities, 

and passenger vessel operations. 

Measure: Percentage of minutes and monitoring reports received within regulatory deadlines or 

formal extension.

 Target: 95% 

Measure: Percentage of new and amended OTI applications that are processed within 45 days. 

Target: 80% 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 8

Outcome Goal 2.2: Conduct educational programs and provide opportunity for informal 

exchanges between our stakeholders and the Commission.

Measure: Number of industry entities invited to address Commission staff. 

Target: 3 

Measure: Presentation, panel participation and attendance by staff at trade conferences. 

Target: 3 

Outcome Goal 2.3: Maintain fair competition in U.S. ocean commerce.

Measure: Achieve positive outcomes in matters for which formal request for additional 

information is made to parties of filed ocean common carrier or marine terminal operator 

agreements. 

Target: 90 % 

Outcome Goal 2.4: Protect the public and users of ocean transportation services from activities 

that violate the shipping statutes. 

Measure: Number of investigations opened to address alleged harm to the public as a result of 

Shipping Act violations.

Target: 50 

Strategic Goal No. 3: Balanced Enforcement

Foster economic efficiencies, reliance on marketplace factors and maritime security by administering U.S. 

shipping statutes in a balanced and equitable manner to redress excessive anticompetitive actions and other 

unlawful activities. 

16 FTEs and $2,861,000.00 will be required to accomplish this goal. 

A. 2009 Steady State Activities:

• Investigating discriminatory rates, charges, classifications, and practices of common 

carriers, terminal operators, and OTIs operating in the foreign commerce of the U.S. 

• Representing the FMC before U.S. courts and other administrative agencies. 

• Reviewing staff recommendations and initial decisions for legal sufficiency and preparing 

final decisions and orders. 

• Regulating rates, charges, and rules of government-owned or -controlled carriers to ensure 

that they are just and reasonable and are not unfairly undercutting private competitors. 

• Protecting shippers and carriers engaged in the foreign commerce of the U.S. from 

restrictive or unfair foreign laws, regulations or business practices that harm U.S. shipping 

interests or ocean trade. 

• Prosecuting formal proceedings initiated by the Commission. 

• Monitoring activities and conducting investigations of regulated entities and of SC activity 

to ensure compliance with statutes and regulations administered by the Commission. 

• Conducting non-adjudicatory fact-finding proceedings as directed by the Commission. 

• Providing liaison between the Commission and the shipping industry, the public and other 

governmental entities. 

• Coordinating and cooperating with other government entities to improve homeland security 

by effective exchange of information and assistance regarding foreign ocean transportation. 
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Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 9

B. Outcome Goals 

 Outcome Goal 3.1: Assure carriers do not exercise their antitrust immunity in a manner that 

results in unreasonable practices, rate increases or service decreases.

 Measure: Percentage of rate agreements analyzed for 6(g) compliance. 

 Target: 100% 

Measure: Number of memoranda, special reports or studies on significant competition related 

issues. 

Target: 3 

Outcome Goal 3.2: Ensure that Commission actions are taken with appropriate consideration of 

their impact on the industry and users of transportation services, including small business 

considerations, and are directed at market-distorting activities. 

Measure: Number of un-addressed comments received in rulemakings regarding SBREFA 

concerns. 

 Target: 0 

Outcome Goal 3.3: Provide regulatory assistance and encourage voluntary compliance with 

shipping statutes and regulations through consistent industry outreach and education efforts.

Measure: Number of compliance presentations by staff to industry and shipping public. 

Target: 3 

Outcome Goal 3.4: Neutralize, or affirmatively address, restrictive trade practices of foreign 

governments.

Measure: Number of unresolved FSPA and Section 19 proceedings. 

Target: No more than 2 

Outcome Goal 3.5: Improve maritime security by curtailing unlawful participation in the U.S. 

ocean transportation system. 

Measure: Percentage of identified unlicensed OTIs sent compliance warning letters. 

Target: 95% 

Strategic Goal No. 4: Technological Efficiencies

Employ technological enhancements to improve efficiency and to facilitate the exchange of information. 

17 FTEs and $2,987,000.00 will be required to accomplish this goal. 

A. 2009 Steady State Activities:

• Implementing a wide range of IT programs and services, including operating the agency’s 

local area network, strategic planning for short- and long-term IT initiatives, IT security, 

data telecommunications, database development and management, and Internet page 

development and maintenance to enhance productivity and efficiency. 

• Maintaining and updating internal databases to enhance the ability of the public and 

Commission to obtain relevant program-related information and enhance staff productivity. 

• Converting Commission records into electronic format to enable easier public access to 

information. 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 10

B. Outcome Goals 

Outcome Goal 4.1: Streamline the Commission's work processes through effective utilization of 

information technology.

Measure: The number of technology solutions that are designed and implemented and used by 

the Commission to facilitate process improvement through the use of databases and record 

keeping systems. 

Target: 6 

 

Measure: Cumulative number of technology solutions that are designed and implemented and 

used by the Commission to facilitate process improvement through the use of databases and 

record keeping systems since FY 2007 (including current fiscal year). 

Target: 12 

Outcome Goal 4.2: Use electronic technology for the receipt of documents filed with the 

Commission as envisioned by the Government Paperwork Elimination Act ("GPEA"). 

Measure: Percentage use of electronically submitted forms by regulated concerns versus receipt 

of traditional paper-driven applications and processes. 

Target: 50% 

Outcome Goal 4.3: Safeguard programs and systems as required by the Federal Information 

Security Management Act of 2002 (“FISMA”). 

Measure: Number of technology-related programs and systems developed or implemented that 

achieve full compliance with Federal information security mandates. 

Target: 12 

Outcome Goal 4.4: Disseminate Commission and staff issuances through the use of electronic 

technology. 

Measure: The total number of visits and downloads from agency website. 

Target: 10 percent increase measured against previous year website traffic statistics, FY 2007 - 

2009. 

Strategic Goal No. 5: Management Capabilities

Ensure the FMC has the appropriate organizational framework and management systems to carry out its statutory 

mandates. 

24 FTEs and $4,217,000.00 will be required to accomplish this goal. 

A. 2009 Steady State Activities:

• Executing financial management policies and programs, including developing annual budget 

justifications for submission to the Congress and OMB, managing agency appropriations, 

administering internal control systems for agency funds, travel and cash management, and 

coordinating with contractors who provide accounting and payroll services. 

• Fostering human resources management principles, including recruitment and placement, 

position classification and pay administration, occupational safety and health, employee 

assistance, employee relations, workforce discipline, performance management and 

incentive awards, employee benefits, career transition, retirement, employee development 

and training, personnel security, and an equal employment opportunity. 

• Ensuring the program operations of the agency are administratively supported via 

telecommunications, procurement of administrative goods and services, property 

management, space, printing and copying, mail and records services, facilities and 

equipment maintenance, and transportation. 
Federal Maritime Commission 

Fiscal Year 2009 Budget Estimates submitted to the Appropriations Committee 11

• Promoting economy and efficiency in the administration of, and protecting and detecting 

waste, fraud and abuse in, the agency’s programs via auditing agency operations. 

• Providing guidance to staff regarding administrative matters, including procurement, 

personnel and contracting issues. 

• Ensuring program compliance with various rules and regulations regarding such areas as 

forms clearance, Paperwork Reduction, Small Business Paperwork Reduction Act, and other 

Federally required reports and submissions. 

B. Outcome Goals 

Outcome Goal 5.1: Organize and manage the agency's staff consistent with established priorities, 

with an emphasis on workforce planning, diversity, and effective internal communication. 

Measure: Percentage of agency employees who participated in required annual training during 

the fiscal year (e.g., ethics, IT security, No FEAR, etc.). 

Target: 100% 

Measure: Number of awareness, recruitment, training, new-employee orientation, 

workforce development, and quality of life initiatives offered to agency employees. 

Target: 250 

Outcome Goal 5.2: Clearly and accurately communicate the Commission's program requirements, 

activities and decisions in a manner consistent with the Information Quality Guidelines for Federal 

Agencies. 

Measure: Percentage of internal Commission orders or SOPs reviewed, developed or updated by 

Office of Administration during the fiscal year. 

Target: 33% 

Measure: Percentage of agency records which have been assessed with respect to records 

disposition requirements with respect to the current fiscal year. 

Target: 33% 

Outcome Goal 5.3: Respond to changing industry conditions and business environment through 

use of state-of-the-art automated systems for internal and external processes and a flexible and 

well-trained workforce. 

Measure: Percentage of agency employees who participated in optional skill-building, 

management and other training during the current fiscal year. 

Target: 25% 

Measure: Percent of payments (user fees, penalties, etc.) received electronically via Pay.gov 

versus older technologies (e.g., checks). 

Target: 25% 

Outcome Goal 5. 4: Enhance performance and accountability through linking planning, financial 

management and performance. 

Measure: Percentage of management officials undertaking reviews of internal controls and 

vulnerability assessments for their programs during the current fiscal year. 

Target: 95% 

 

Measure: Number of material deficiencies found in most recent financial statement audit. 

Target: 1 or fewer 

Measure: Received “unqualified opinion” from financial statement auditors with respect to the 

current fiscal year. 

Target: Yes