Meeting the Transportation Needs of Rural Communities
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Photo: Kevin Dooley
Meeting the Transportation
Needs of Rural Communities
Lessons That Cannot Be Learned from Urban Transit
R
ural transit did not become part automobiles became the preferred mode
PETER SCHAUER of the social milieu of the United of travel and employers and employees
States until 1964, when President moved to the suburbs, however, the tran-
The author is Principal, Peter Lyndon B. Johnson’s War on Pov- sit industry started to lose its share of the
Schauer Associates, Boonville, erty produced an array of new market and did little in response to attract
federally supported services. Rural transit new passengers or keep old ones. Transit
Missouri. He is emeritus member
has a short history—about 50 years—but rapidly became the conveyance for those
of the TRB Rural Public and urban transit and its planning have been who had no other choice (3).
Intercity Bus Transportation around for much longer. The Industrial Rural transit then burst onto the
Committee. Revolution in the 18th and 19th centuries transportation scene, new and somewhat
meant that people no lon-
Photo: Philly History.org
ger worked at home and
needed a way to travel to
factories, which urban
transit provided (1–2).
When in the 20th cen-
tury mass-produced
The Industrial
Revolution of the
18th and 19th
centuries created
a need for urban
transit, as people
Above: Federal services introduced by sought ways to
Johnson’s War on Poverty in the mid-1960s travel to factories
ushered in new attention to rural transit. for work.
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amorphous (Figure 1, below). It was the (AAAs) and authorized the formation of
result of a combination of factors—some local Community Action Agencies (CAAs),
shared with urban areas, such as the respectively, as part of the War on Poverty.
dominance of the automobile as a mode of AAA units established senior gathering
travel, and some unique, such as the need places (senior centers), which included
to support travel over long distances to ser- nutrition sites for dining and other health
vices and trades. Unlike urban transit, rural and recreation programs for senior citizens.
transit has no prescribed federal planning Similarly, CAAs established a wide range
requirements for a transit development of social services—including job training,
plan; that is, a wide range of activities and youth development, energy assistance and
Photo: Peter Schauer
service types can emerge to fit the multi- home weatherization, and more—to elimi-
tude of unique conditions found in rural The first annual Missouri Transportation nate poverty and its root causes. According
Workshop, sponsored by OATS, took place
America. Even the term “rural” has various in September 1975 at Camp Cloverpoint in to the Connecticut Association for Com-
meanings: for some, it may mean the lack Kaiser, Missouri. munity Action website, “the Community
of population density; for others, it may Action Program would serve the role of
mean distance to a metropolitan area or to- found in rural areas, only 6% of federal out- helping members of the community access
tal population of a given geographic area. lays for public transportation in fiscal year the services they needed on the communi-
The accepted definition of “rural” used (FY) 1976 was allocated to rural areas (4). ty level, with the ultimate goal of guiding
in the field of rural passenger transporta- The inequity of the distribution of the people benefiting from the services to
tion in the United States—and used by the funds was a rallying point for a growing independence and sustainability” (6).
U.S. Department of Transportation (DOT) number of rural transit providers and social Central to both OAA and EOA was the
to administer Section 5311 Rural Area For- service advocates in the late 1960s and independence and sustainability of the
mula Program Grants—is any area that is early 1970s. These groups emphasized the people they were intended to serve. OAA
not urbanized; that is, any area that does need for rural passenger transportation, enhanced the independence and sustain-
not have a population of 50,000 or more. which became evident in the early 1970s ability of older people to live in their own
as a result of the social services established homes and EOA enhanced the indepen-
Rural Transit Is Not by the Older Americans Act of 1965 dence and sustainability of low-income
Miniature Urban Transit (OAA) and by the Economic Opportunity people. Both CAAs and AAAs quickly
Rural transit is not miniature or scaled- Act of 1964 (EOA). These two pieces recognized that independence and sus-
down urban transit. The term “rural of legislation established state units on tainability could not be achieved without
transit” refers to a service available to the aging and local Area Agencies on Aging accessibility to services, and they set about
public in a vehicle of varying types and
dimensions. The vehicle generally is rub- Federal-Aid Highway Act of 1973
0.0000110% Section 147 Authorized Rural Public
ber-tired or waterborne. By comparison, Transit Demonstrations
urban transit can have these same attri- 0.0000100%
Urban Mass Transportation Act of 1964
First Urban Capital Assistance
butes, but also can include light rail, heavy
0.0000090% National Mass Transportation Assistance Act of 1974
commuter rail, trolleys, and more. Economic Opportunity Act of 1964 Urban Capital and First Operating Assistance
To think of rural transit as miniature 0.0000080%
urban transit unfairly characterizes the Surface Transportation Act of 1978
0.0000070% Older Americans Act of 1965 Urban Capital and Operating Assistance
differences between rural and urban com- Rural First Capital and Operating Assistance
munities and their transportation needs. 0.0000060%
Early rural transit advocates perceived a
0.0000050% Surface Transportation and Uniform Relocation
degree of unfairness and felt the amount Assistance Act of 1987
Urban Capital and Operating Assistance
of funding rural transit was receiving in 0.0000040% Rural Capital and Operating Assistance
Rural Transit Assistance Program Authorized
comparison with urban areas was not
0.0000030%
equitable. They believed that it was not
fair for rural transit to receive no federal 0.0000020%
funding support when urban transit was Urban transit
receiving federal support. 0.0000010%
In 1977, before the Surface Transpor- 0.0000000%
Rural transit
tation Act of 1978 was enacted—the most 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005
significant legislation supporting rural tran-
FIGURE 1 Significant milestones in rural transit (red ) and urban transit (blue) and their
sit—the Rural America Organization stated
relative term mention in books, 1960–2008 (5).
that although 60% of low-income need was Note: Highway Research Board was renamed the Transportation Research Board in 1974.
TR NEWS J a n u a r y – F e b r u a r y 2 0 2 0
› 11
With no federally mandated planning gument about transit perhaps allows urban
practices for early rural transit develop- transit to be called a utility, based on its
ment, advocates instead argued that plans necessity for commerce, labor movement,
should be based on people’s need to access and the environment. Rural public transit
social and medical services in order to have functions more as a social service, and
sustainable and independent lives. Simply the funding mechanisms described below
making sure that people and goods can further bolster this conclusion.
move does not translate into accessibility of
needed services and goods. Conventional Discovery Through
Photo: Knox County Government
mobility planning has resulted in a trans- Demonstrations
portation system that primarily supports For advocates and state DOT officials in
Rural transit programs enable seniors
in Knox County, Tennessee, to live more
private automobile travel—but how does the early 70’s, it became clear that rural
independently and to pursue interests. this serve those without access to a car? public transit required a different approach
What would it mean, then, to refocus to planning and implementation of ser-
transportation planning on accessibility vices. Transportation planners would have
establishing formal and ad hoc transit rather than simply on mobility? Without to respond in new and different ways, par-
programs for the people who needed their set standards, this would be difficult. Even ticularly when planning for persons who
services. The number of rural services of all the most obvious service standards (for are elderly or disabled, of whom there
types grew exponentially (7). example, seven-day-a-week transit service are proportionately more in rural than in
A variety of service types were im- that offers an alternative to an automobile urban areas (9).
plemented, even voucher-type services and allows a person to live a sustainable When CAAs and AAAs developed early
that used private taxis. Some services had and independent life) are extremely rare in transportation services, these agencies
purpose-built vehicles with specialized rural settings—and even in urban settings, were not quantitatively or logistically
wheelchair lifts, and others simply provid- for that matter. sophisticated. Their programs needed
ed services with government surplus mil- Without measureable standards such as participants and participants needed the
itary buses.1 CAAs and AAAs both made ac- those for highways, it is difficult to define programs but could not access them,
cessibility a high priority; the ultimate goal rural public transit as a utility versus a social so CAAs and AAAs initiated passenger
of their transportation efforts was ensuring service. The utility-versus-social-service ar- transportation services to support their
that all their services were accessible.
Planning and
Understanding Demand
How much transportation can allow a rural
person to have an independent and sus-
tainable life? Even after approximately 40
years of federal involvement in rural public
transit—and 50 years of federal involve-
ment in urban transit—it has not been rig-
orously established what exactly constitutes
sufficiency in mobility or accessibility in
order for transportation users to maintain a
minimum standard of living (8). Thus, rural
transit struggles to make the case for public
financial support based on conventional
transportation planning programs, as the
strict focus on maximizing the mobility of
people and goods does not work.
1
Highlights of the development of AAAs and
CAPs—creative, innovative programs that ranged
Photo: David Wilson, Flickr
from West Virginia’s TRIP program, modeled
after food stamps, to a wide range of paratransit Missouri’s OATS Transit provides deviated–fixed routes and medical, senior, toddler,
services—are presented in the history of TRB Rural preschool, and general rural transportation to 97 counties in the state—making it the
Committee. For more, see Schauer (10). largest and most unique system of its kind in the country.
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general mission of independence and sus- TABLE 1 Percent of Total Operating Budget for Rural Public Transit (10–11)
tainability. Since many people could not
sustain their lives independently without FUNDING SOURCE 1985 (%) 2015 (%) TREND
transportation, the agencies provided
Federal 26.5 34.0
whatever passenger transportation their
State 11.0 19.0
budgets would allow, rather than con-
ducting a thorough analysis of community
Local 43.7 26.0
needs. Eventually, more-sophisticated and Fares 27.8 a
9.0 NA
more-frequent analysis was performed as Contracts NAa 10.0 NA
more federal funds became available and a
Data for contracts and composition of fares in 1985 are not available. It is likely that fares included contract
as some states began to require planning revenues.
procedures, but these analyses were not
necessarily more precise in their approach-
es to quantify need or demand.2
Validating need and demand through in aggregate and as a percentage of oper-
Because of this, early practitioners
demonstrations was formalized through ating costs (see Table 1, above).
of rural public transit or rural specialized
the Federal Aid Highway Act of 1973 Despite those concerns, states sup-
passenger transportation typically used
Section 147, the Rural Highway Public ported the concept of rural public transit
two traditional methods of planning and
Transportation Demonstration Program. but were somewhat stunned to find that
implementing services: demonstrations
This was the first federally funded ini- they were having difficulties obligating
and peer group comparisons. The most
tiative for rural transit to recognize the all their new Section 18 funds. Upon
successful of the demonstration approach
transportation needs of rural America as a examination, it turned out that this was
is Missouri’s OATS program (previously
legitimate part of the nation’s emerging due to the requirement that operating
the Older Adults Transportation Service,
transportation policy. In 1974, funds were grants be matched 50% with local funds.
now formally titled Operating Above the
appropriated and by 1979, 134 projects For example, a $100,000 project with a
Standard), the largest rural public transit
were awarded—at least one in every state. grant request for $50,000 in Section 18
system in the United States.
Some of those projects continue to this operating funds had to be matched with
In the early 1970s, the Missouri state
day, but more than a few were discontin- $50,000 in local unrestricted funds. For
unit on aging reportedly offered funds to a
ued or consolidated into larger efforts as many potential rural transit projects, it was
group of senior citizen advocates to study
rural public transit funding became avail- impossible to secure 50% hard-cash, local
the problems of older adult transportation
able through the Surface Transportation funds for a match.
in Missouri, but the advocates instead
Assistance Act of 1978, which included a
pursued a demonstration grant of $30,259
funding source specifically for rural public Local Match Redefined
for the actual operation of a small bus The redefinition of “local match” was a
transit in its Section 18.
service. The August 9, 1971, minutes of boon for rural transit. This began in the
By this time, a wide variety of services
the OATS founding committee documents state of Texas, which had obligated only
had dedicated funding sources, so transit
the discussion of the founders, in which 35% of its FY 1980 funds as of May 31,
advocates began asking questions to eval-
they concluded: “We will be a demonstra- 1983 (12). Transit advocates and service
uate these services to get a better sense of
tion project and if we can show a need providers in Texas were understandably
the need, demand, and operational costs
for this program and it is a success we can concerned until Austin-based transit
for services. These all became pertinent
then expand to other counties and ask for consultant Peter Canga devised a solution
questions, especially for state officials who
a larger grant.” From that small begin- to the local match problem that ultimately
were concerned about substituting U.S.
ning—with three 15-passenger maxi-vans changed the nature of rural transit. Canga
DOT Section 18 funds for previously ded-
operating in four counties—OATS eventu- understood both the heritage of rural tran-
icated U.S. Department of Health and Hu-
ally grew to its current size: 800 vehicles sit as a social service and the workings of
man Services social service funds provided
and 700 employees providing services in federal grant programs; through creativity
by AAAs, CAAs, and similar organizations.
87 counties, with an operating budget of and persistence, he was able to secure a
Although the data are not conclusive,
$28,992,420 (9). The need for OATS has memo from the Federal Highway Adminis-
the trend has been toward increased
been demonstrated. tration dated August 1982, which stated:
federal and state support of rural transit
as a percentage of operating costs and a “funds obtained by a Sec. 18 operator
reduced percentage from local sources. through purchase of service contracts with
2
For more on problems of predicting need or Of course, the amount and total operat- a human service agency may be used for
demand for rural public transit, see Schauer ing costs of services have increased since local match without any restrictions” (12).
(10). For more on problems of predicting need
and demand for persons with disabilities, see 1978, but in general, federal and state The implementation of this new matching
Rosenbloom (7). dollars for rural transit have increased both procedure required a 1985 amendment to
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Public Transit in
Native American
Communities
Early Beginnings and Progress
T he Johnson administration provided additional social service
funding to American Indian tribes and reservations and, in
1968, called for an end to previously active tribal termination pro-
bad relationships between the Tribe and the state,” tribes would
not receive a fair and equitable distribution: “state pass-through
funding is also a departure from the historical practice in which
grams (1). As a result of Johnson’s War on Poverty, tribes started the sovereign Indian tribes always maintained a unique and direct
providing transportation to specific social services in the 1960s. relationship with the Federal government” (3).
In addition to the growth of social services and the accompa- In the face of these concerns, the Menominee Indian Tribe of
nying need to transport people to those programs, the emer- Wisconsin, through a feasibility study provided by the Wisconsin
gence and growth of tribal rural public transportation also was Department of Transportation in 1980, implemented a coordi-
heavily influenced by public transit demonstrations. In 1975, as nated Section 18 program. Menominee Regional Public Transit
part of the Federal Highway Administration’s Section 147 demon- (MRPT) “represents a synergistic partnership of agencies on and
stration program, 11 demonstrations were conducted for tribal off the reservation” that enabled the service to provide transit to
organizations within Indian reservations and communities (2). Indians and non-Indians (4). Today, MRPT is one of the largest
Although seven of the 11 Section 147 projects ended when and most successful public transit services of any type in the
the demonstrations terminated in 1979, many stakeholders United States.
hoped the others would find continued funding through the newly Most tribes did not access Section 18 funds because local
available Section 18 of the Surface Transportation Assistance Act matching funds were lacking and because of other concerns
of 1978 (3). Some expressed concern that, because Section 18 about signing required federal certifications and assurances,
was allocated by formula to states and there was a “history of particularly transit labor protection certification 13(C). In 1999,
the Urban Mass Transportation Act that, of information, however. In late 1980, the such notables as Arthur Saltzman and
interestingly, did not apply to urban transit Community Resource Group in Springdale, Norm Paulhus to local transit managers
grants (10). Arkansas, set about collecting information like Terry Young.
through a system called Rural Transpor- A training conference on how to use
Origins of the Rural tation Information (RTI), a practical rural the RTI program was held in March 1981
Transit Assistance transit technology transfer program (13). in San Antonio, Texas. Attendees remarked
Program The RTI program consisted of the that this was the first time that rural public
following: transit was recognized as an identifiable
RURAL TRANSPORTATION
INFORMATION 1. A file box with files labeled for unbound field of endeavor and study. RTI became
Although they were not subject to material, the model for the Rural Transit Assistance
project-intensive federal planning re- Program (RTAP).
2. A file system for bound material, and
quirements, rural transit providers still RTI and the directories of practitioners,
3. A file box and system for contacting administrators, and experts supported the
wanted to implement best practices and
people in the rural transit field—a advancement of rural transit as a recog-
interact with other practitioners. They
collection of some 300 names, from nized field of study. At the same time,
lacked a widely recognized single source
14
‹ TR NEWS J a n u a r y – F e b r u a r y 2 0 2 0A Menominee Regional
Public Transit driver assists
a passenger at the Tribal
Health Clinic, Keshena,
Wisconsin. (Photo: Peter
Schauer)
it was reported that only 18 of 562 federally recognized tribes REFERENCES
received any funding from the Federal Transit Administration 1. Crain, J., and E. Hodson. Rural Transportation Projects on Indian
(FTA) rural transit program. Reservations: A Report on Eleven Demonstrations. Report UMTA-
MA-06-0049-80-8. U.S. Department of Transportation, 1980, p. A12.
It was not until the FTA tribal transit program came into
2. Crain and Hodson, p. 5.
effect in 2006—with a discretionary funding program and a
direct funding and application route to FTA, thereby circumvent- 3. Crain and Hodson, pp. 44–45.
ing states—that tribal transit programs grew vigorously, to 132 4. Stoddard, A., D. Sampson, J. Cahoon, R. Hall, P. Schauer, V. J.
Southern, and T. Almeida. TCRP Web-Only Document 54: Developing,
programs in 2015 (5). In 2012, the tribal transit program was Enhancing, and Sustaining Tribal Transit Services—Final Research Report.
revised to include a discretionary and formula component (6). Transportation Research Board, 2012, p. 77.
The growth of tribal public transit and the recognition of 5. Mattson, J. 2017 Rural Transit Fact Book. Report SURLC 17-
its importance is summarized in the following report from the 007. Small Urban and Rural Transit Center, Upper Great Plains
Transportation Institute, North Dakota State University, 2017, p. 51.
National Congress of American Indians on a survey of transit ser-
vices on reservations: “far from being a mere detail in the tribe’s 6. F TA Tribal Transit Program. National Rural Transit Assistance
Program. www.nationalrtap.org/Tribal-Transit/FTA-Tribal-Transit-
efforts to improve their material well-being and standard of living Program. Accessed Nov. 12, 2019.
for their members, viable transit systems is the glue that holds 7. National Congress of American Indians, R. Holden, and P.
tribal economies and societies together” (7). Moorehead, eds. National Indian Tribal Transit Report. Federal
—Peter Schauer Transit Administration, U.S. Department of Transportation, March
1996, p. 53.
Boonville, Missouri
many advocacy and interest groups be- TRANSPORTATION CAMP Point in Lake of the Ozarks State Park for
yond those associated with AAAs and CAAs The advocates who started the success- a three-day camp to discuss transit needs.
became active in the advancement of both ful OATS demonstration in Missouri also This was part of the new way of thinking:
the study and funding of rural transit. The recognized that a new way of thinking was to involve the potential users in designing
U.S. Department of Agriculture’s National needed, and they subsequently founded and managing the service.
Rural Development Council, the National a concept called “Transportation Camp.” The OATS transportation camp was
Rural Coalition, the National Rural Center, For three years beginning in September true citizen advocacy—the highlight and
and (most notably) Rural America all 1975, OATS sponsored a transportation focal point of the event was a discussion
became strong advocates for the funding camp and workshop that brought togeth- of each county’s transit needs, as prepared
and implementation of rural public transit. er hundreds of nonexperts to focus on the by a local resident of that county (15). The
Rural America seemed to capture the most rural transit needs of the entire state, not people who needed the service organized
attention with their 1979 report “Research just of the four counties that OATS initially and advocated to meet their needs and
Report 3: Rural Transportation—A Modest served. OATS rural transit pioneers invited those of their community.
Proposal,” which offered a different way to elected officials, state and federal officials, In 1982, Rural America received an
plan and implement rural transit (14). and actual transit riders to Camp Clover Urban Mass Transportation Administration
TR NEWS J a n u a r y – F e b r u a r y 2 0 2 0
› 15likely that transit would have a different,
less-expansive role in rural America. It was
advocacy by people—often riders of rural
transit who brought issues of equity before
Congress in the early 1970s—that resulted
in dedicated federal funding. Today,
researchers, policymakers, and politicians
explore rural and urban equity issues, and
the need for transit funding of all types re-
mains paramount, especially to the people
addressed by the OAA and EOA.
REFERENCES
1. Smerk, G. M. Public Transportation and the
City. In Public Transportation, 2nd ed. (G.
E. Gray and L. A. Hoel, eds.), Prentice Hall,
Englewood Cliffs, N.J., 1992, pp. 3–23.
2. Dejean, J. How Paris Became Paris: The Inven-
Photo: TriMet, Flickr tion of the Modern City. Bloomsbury, New
York, 2014, p. 126.
Throughout the 1970s and 1980s, federal, state, and local agencies met with 3. Saltzman, A. Public Transportation in the 20th
community members to design and manage rural transit programs that would fit Century. In Public Transportation, 2nd ed. (G.
the needs of county residents. E. Gray and L. A. Hoel, eds.), Prentice Hall,
Englewood Cliffs, N.J., 1992, pp. 24–45.
4. Rural America Factsheet #6: Public Transpor-
(UMTA) discretionary grant to advance RTAP has continued well beyond those
tation. Rural America Organization, Washing-
rural transit. The UMTA Administrator initial five years and serves as a reminder ton, D.C. Circa 1978.
at the time had desired more practical of the effectiveness of peer group assis- 5. Michel, J.-B., et al. Quantitative Analysis of
Culture Using Millions of Digitized Books. Sci-
materials on the implementation and tance and the evolution of rural transit.
ence, Vol. 331, No. 6014, 2011, pp. 176–182.
operation of rural transit, so with Rural Through an advisory board of state RTAP 6. History. Connecticut Association for Commu-
America’s community-based advocacy, managers and rural transit practitioners, nity Action. www.cafca.org/history. Accessed
October 31, 2019.
a work program was developed. This the program remains focused on practi-
7. Rosenbloom, S. The Transportation Disadvan-
program combined elements of the OATS cal and rural transit training needs. The taged. In Public Transportation, 2nd ed. (G.
transportation camp, RTI, and peer-to- systematic manner in which RTAP has cat- E. Gray and L. A. Hoel, eds.), Prentice Hall,
Englewood Cliffs, N.J., 1992, pp. 583–616.
peer exchanges and ultimately resulted alogued information and shares it through
8. Dempsey, P. S. The Social and Economic
in creation of the National Association of a website, conferences, and one-on-one Consequences of Deregulation: The Transporta-
Transportation Alternatives (NASTA), the technical assistance has made it a unique tion Industry in Transition. Greenwood Press,
Westport, Conn., 1989, p. 385.
first organization focused on rural public resource that has no equivalent activity in
9. D. Yeager, personal communication, Nov. 1,
and community transportation. Eventually, the field of urban transit. 2019.
both NASTA and Rural America combined 10. Schauer, P. Rural Public Transportation. In Pub-
to form a new organization, Community Conclusion lic Transportation, 2nd ed. (G. E. Gray and L.
A. Hoel, eds.), Prentice Hall, Englewood Cliffs,
Transportation Association of America, Rural transit emerged via forces quite N.J., 1992, pp. 407–444.
which continues today. different from those that gave rise to 11. Mattson, J. 2015 Rural Transit Fact Book.
urban transit. Urban transit has had a Report SURLC 15-001. Small Urban and Rural
In 1987 the Surface Transportation
Transit Center, Upper Great Plains Transporta-
and Uniform Relocation Assistance Act long-standing role in cities that dates back tion Institute, North Dakota State University,
was passed. The transit appropriations bill hundreds of years; rural transit came about 2015.
only decades ago, spurred by the lack of 12. FY 1980 Sec. 18: Use It or Lose It. Rural Trans-
included $5 million per year for five years
portation Reporter, Vol. 1, No. 4, Aug. 1983,
to implement RTAP, which in many ways commerce, available services, growth, and p. 1.
formalized the RTI concept along with development in rural areas. People in rural 13. Schauer, P. Rural Transportation Information:
areas needed services, and social service User Guide. Community Resource Group,
elements of Rural America’s first UMTA
Springdale, Ark., 1981.
discretionary grant. According to the 1987 providers discovered that they needed to 14. Moore, J. Rural Transportation: A Modest Pro-
UMTA Acting Director Alfred DelliBovi, be transit providers. Social service agen- posal. Research Report 3. Rural America, Feb.
cies still are key providers of rural transit, 1979, p. 1.
“RTAP will have a wide range of activities
15. First Annual Missouri Transportation Work-
such as training courses; ‘circuit riders’ to through contracts that provide large reve- shop. Sept. 1975, p. 14.
give onsite training on safety, maintenance, nues to match federal grants. 16. The Rural Transit Assistance Program: A New,
Without the 1985 amendment to the National Training Resource. Community Trans-
management, etc.; peer-to-peer networks;
portation Reporter, Vol. 5, No. 7, July–August
information exchanges such as computer UMTA that allowed social service con- 1987, p. 8.
bulletin boards; and newsletters” (16). tract revenues to be used as a match, it is
16
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