1. GROTON-DUNSTABLE REGIONAL SCHOOL DISTRICT
School Transportation Efficiency Study
and
Later High School Start Time Analysis
January 10, 2019
Public Management Associates, LLC
47 Bigwood Drive
Westfield, MA 01085

2. STUDY OBJECTIVES
1. Determine the Cost Effectiveness and Efficiency of the Current Transportation Operation with Recommendations for Improvement
2. Review Various Alternatives for a Later Start Time for the High School which will:
* Start the High School at 8:30 a.m.
* Minimize any Elementary and Middle School Schedule Changes
* Maintain the Current Length of School Day for All Schools
* Minimize Student Time on Vehicles to Minutes or Less with Convenient Bus Stops
* Be as Cost Neutral as Possible

3. DEFINITIONS
TIER TIME: A tier is defined as that time which is available prior to the start of the earliest school, the time between the starting time of the earliest school and the starting time of the next earliest school and the time between the starting time of the second earliest and that of the third earliest school.
ROUTE TIME: The time from the bus depot to the actual school drop off time (includes 6-7 minutes of disembarking time).
RIDE TIME: The time from the time of the first student pick up to the last student drop off (either at school or at home).
DEAD HEAD TIME: Time from the end of 1 route to the start of the next route in which there are no students.

4. SCHOOL TRANSPORTATION EFFICIENCY
School transportation efficiency is generally determined by the following factors:
Manual vs. computerized routing and scheduling
The person who does the routing and scheduling determines the number of buses required.
Community expectations for quality of service, i.e. short routes and/or convenient bus stops
Student Riders: Scheduled vs. Actual Riders (Student Loading)
Time available between school starting and ending times (Tiers)
Distances and travel time between schools
Population density, i.e. number of students per mile of bus travel
Highway / road infrastructure and traffic patterns and congestion
A.M. routes generally drive the number of buses required, as more students ride in the morning than in the afternoon due to after school activities.

5. CAVEAT
Transportation management can sometimes “over consolidate” routes in order to eliminate a bus, only to have to reinstate it during the year or the following year due to required changes or routes which are too long. As a result an efficient transportation system requires some “excess” capacity in order to manage the routes and schedule changes from year to year in order to not have to add a bus and driver during the year and after the budget has been set.

6. DEMOGRAPHICS
Population (2010): 13,825 Geographic Area: 50.4 Square Miles Populations Density: 274 Persons/Square Mile Traffic Congestion (A.M. Drive Time): Low School Traffic Congestion (A.M & P.M.): Moderate Community Expectations: High Distance between Middle School and High School: 4 miles Therefore, based upon the preceding, school transportation efficiency is determined by other than strictly student ridership, such as school bell schedules (tier times), route time and school distances, as well as community expectations for high quality service.

7. UNSCHEDULED TIER BLOCKS
BUS FLEET UTILIZATION
The District currently transports approximately 1558 students, utilizing passenger buses with a seating capacity of 51 students for high school and middle school age students. Based upon these parameters, the District routes consist of the following:
HIGH SCHOOL 18
MIDDLE SCHOOL 16
ELEMENTARY SCHOOLS
3 TIER ROUTES 16
2 TIER ROUTES 2
1 TIER ROUTES
UNSCHEDULED TIER BLOCKS

8. TRANSPORTATION BUDGETS vs. DISTRICT BUDGETS
COST EFFECTIVENESS
TRANSPORTATION BUDGETS vs. DISTRICT BUDGETS
FY'2014
FY'2015
FY'2016
FY'2017
FY'2018
FY'2019
TRANSPORTATION BUDGETS
$ 1,514,100
$ 1,930,578
$ 1,894,195
$ 1,928,600
$ 2,061,006
$ 2,096,042
DISTRICT BUDGETS
$ 35,200,000
$ 35,696,179
$ 36,449,830
$ 38,210,905
$ 39,425,831
$40,747,662
% TRANSPORTATION/ DISTRICT BUDGETS
4.30%
5.41%
5.20%
5.05%
5.23%
5.14%
FINDING: For Districts with similar demographics, a transportation budget of 5.5 % or less of the total district budget is considered cost effective by current industry standards.

9. ROUTING EFFICIENCIES
COMMENDATION: The Director of Business and Finance is relatively proficient with the Transfinder routing software and knowledgeable of the District transportation requirements, as well as community expectations. All data was readily available and answers to questions and explanations were provided. He does an excellent job in managing the transportation operation within the quality constraints required. FINDING: The Transfinder routing software may not be robust enough to provide the optimum in routing efficiencies, especially in considering revising school bell schedules. FINDING: Many of the current routes make numerous stops within relatively short distances. RECOMMENDATION: The District may wish to consider acquiring the Traversa (Tyler Technologies) routing software. The tools would be more helpful in considering school redistricting, shifting bell schedules and is much more intuitive in routing efficiencies.

10. SCHOOL TIMES/TRANSPORTATION TIER TIMES
START
END
A.M.
P.M.
LENGTH
SCHOOL
TIME
TIER TIME
of DAY
HIGH SCHOOL
7:27
1:50 50
6'23"
MIDDLE SCHOOL
8:08
2:25 41
35*
6'17"
SWALLOW UNION ELEMENTARY
8:55
3:20 47 55
6'25"
FLORENCE ROCHE SCHOOL
BOUTWELL SCHOOL
12:30 35
*Relatively short transportation time
The District schools have different lengths of school day:
High School: 6 Hours 23 Minutes
Middle School: 6 Hours 17 Minutes
Elementary Schools: 6 Hours 25 Minutes
FINDING: This length of school day variance may have a significant impact on the ability to restructure school start/end times and maintain both transportation efficiencies.

11. CURRENT ROUTE INFORMATION HIGH SCHOOL ROUTES
BUS
DESCRIPTION
START
END
ROUTE
TIER
NUMBER
SCHED.
ACTUAL
LOAD
NO.
TIME
MILES
STOPS
CAPACITY % 1 HS
6:24
7:10
0:46 50
16.28 21 34 9 51
18% 2
6:40
6:56
0:16
5.21 13 26 7
14% 3
6:41
7:02
0:21
6.61 16 25 14
27% 4
6:37
7:00
0:23
7.3 10 15 8
16% 5
6:42
0:18
6.01 6
6:36
6:59
8.43 12
7:05
9.67 11 28
6:55
7:20
0:25
9.12 38
41%
6:58
6.37 42
20%
6:31
0:34
11.65 44 19
37%
6:45
7:11
0:26
8.68 23
29%
6:32
0:28
9.76 22 46
31%
7:04
10.46 20
43%
0:40
13.15 48
67%
7:09
0:24
6.72 45
6:35
7:08
0:33
11.18 49 17
7:07
7.45 18 35
7:06
0:30
10.21 39 30
59%

12. HIGH SCHOOL ROUTES OPERATIONAL METRICS
A.M. ROUTES
P.M. ROUTES
NO. BUSES 18
NO. RTS.
SCHED. LOAD
592
ACTUAL LOAD
292
CAPACITY
918
AVE. SCHED. LOAD/RT.
32.9
AVE. ACTUAL LOAD/RT.
16.2
AVE. TIME/RT.
26.8
AVE. TIME/BUS
AVE. MILES/RT.
9.1
AVE. MILES/BUS
AVE. STOPS/RT.
16.7
SCHED. LOAD/CAPACITY RATIO
64.5%
ACTUAL LOAD/ CAPACITY RATIO
31.8%
NO. BUSES 18
NO. RTS.
SCHED. LOAD
590
ACTUAL LOAD
333
CAPACITY
918
AVE. SCHED. LOAD/RT.
32.8
AVE. ACTUAL LOAD/RT.
18.5
AVE. TIME/RT.
28.1
AVE. TIME/BUS
AVE. MILES/RT.
9.3
AVE. MILES/BUS
AVE. STOPS/RT.
16.3
SCHED. LOAD/CAPACITY RATIO
64.3%
ACTUAL LOAD/ CAPACITY RATIO
36.3%

13. HIGH SCHOOL STUDENT LOADING ANALYSIS A.M. ROUTES
ROUTE NUMBER

14. HIGH SCHOOL ROUTE TIME ANALYSIS A.M. ROUTES
(MIN.)
ROUTE NUMBER

15. CURRENT ROUTE INFORMATION MIDDLE SCHOOL ROUTES A.M. ROUTES
BUS
DESCRIPTION
START
END
ROUTE
TIER
NUMBER
SCHED.
ACTUAL
LOAD
NO.
TIME
MILES
STOPS
CAPACITY % 2 MS
7:21
8:00
0:39 41
10.78 21 50 44 51
86% 3
7:55
0:34
10.43 16 22 26
51% 4
7:20
0:40
14.26 14 24
47% 5
7:03
0:57
17.78 19 34
67% 6
7:38
0:22
6.65 15 28
37% 7
7:24
0:36
12.19 23 38 36
71% 8
0:31
7.11 30 56 45
88% 9
7:27
0:28
9.09 20 52 39
76% 10
10.46 49 11
7:29
0:26
7.49 12
7:25
0:35
9.93 25 59
102% 13
7:30
0:30
9.44 48
100%
12.72 55
8.93 37
73% 17
7:33
0:27
6.8 47
80% 18
7:35
0:25
8.4

16. MIDDLE SCHOOL ROUTES OPERATIONAL METRICS
A.M. ROUTES
P.M ROUTES
NO. BUSES 16
NO. RTS.
SCHED. LOAD
709
ACTUAL LOAD
613
CAPACITY
816
AVE. SCHED. LOAD/RT.
44.3
AVE. ACTUAL LOAD/RT.
38.3
AVE. TIME/RT.
37.0
AVE. TIME/BUS
AVE. MILES/RT.
10.3
AVE. MILES/BUS
AVE. STOPS/RT.
21.8
SCHED. LOAD/CAPACITY RATIO
86.9%
ACTUAL LOAD/ CAPACITY RATIO
75.1%
NO. BUSES 16
NO. RTS.
SCHED. LOAD
709
ACTUAL LOAD
599
CAPACITY
816
AVE. SCHED. LOAD/RT.
44.3
AVE. ACTUAL LOAD/RT.
37.4
AVE. TIME/RT.
33.2
AVE. TIME/BUS
AVE. MILES/RT.
10.2
AVE. MILES/BUS
AVE. STOPS/RT.
21.6
SCHED. LOAD/CAPACITY RATIO
86.9%
ACTUAL LOAD/ CAPACITY RATIO
73.4%

17. MIDDLE SCHOOL STUDENT LOADING ANALYSIS A.M. ROUTES
ROUTE NUMBER

18. MIDDLE SCHOOL ROUTE TIME ANALYSIS A.M. ROUTES
(MIN.)
ROUTE NUMBER

19. CURRENT ROUTE INFORMATION ELEMENTARY SCHOOL ROUTES
BUS
DESCRIPTION
START
END
ROUTE
TIER
NUMBER
SCHED.
ACTUAL
LOAD
NO.
TIME
MILES
STOPS
CAPACITY % 1 SU
8:01
8:45
0:44 47
14.2 22 32 28 77
36% 3
8:18
0:27
8.71 30 23
30% 4
5.97 61 54
70% 5
8:11
0:34
9.15 35
45% 7
8:15
8:49
10.31 20 16
21% 9
8:13
0:32 25 42 36
47% 10
8:09
0:36
9.83 21 38 31
40% 2 FR
8:07
0:38 63 33
43% 6
11.9 26 53 41
53% 8
8:20
0:25
8.12 15 34
39% 11
8:19
0:26
7.81 37
42% 12
8.68 66 58
75% 13
0:30
10.13 24 40
55% 14
8:21
0:24
6.89
34%
9.23 29 50
65%
8.95 18 17
8.9
48%
9.03 69 43
56%

20. SWALLOW UNION ELEMENTARY SCHOOL ROUTES OPERATIONAL METRICS
A.M. ROUTES
P.M ROUTES
NO. BUSES 7
NO. RTS.
SCHED. LOAD
287
ACTUAL LOAD
223
CAPACITY
539
AVE. SCHED. LOAD/RT.
41.0
AVE. ACTUAL LOAD/RT.
31.9
AVE. TIME/RT.
33.4
AVE. TIME/BUS
AVE. MILES/RT.
9.8
AVE. MILES/BUS
AVE. STOPS/RT.
22.9
SCHED. LOAD/CAPACITY RATIO
53.2%
ACTUAL LOAD/ CAPACITY RATIO
41.4%
NO. BUSES 7
NO. RTS.
SCHED. LOAD
289
ACTUAL LOAD
206
CAPACITY
539
AVE. SCHED. LOAD/RT.
41.3
AVE. ACTUAL LOAD/RT.
29.4
AVE. TIME/RT.
35.3
AVE. TIME/BUS
AVE. MILES/RT.
9.2
AVE. MILES/BUS
AVE. STOPS/RT.
22.3
SCHED. LOAD/CAPACITY RATIO
53.6%
ACTUAL LOAD/ CAPACITY RATIO
38.2%

21. SWALLOW UNION ELEMENTARY SCHOOL STUDENT LOADING ANALYSIS A.M. ROUTES
ROUTE NUMBER

22. SWALLOW UNION ELEMENTARY SCHOOL ROUTE TIME ANALYSIS A.M. ROUTES
(MIN.)
ROUTE NUMBER

23. FLORENCE ROCHE ELEMENTARY SCHOOL ROUTES OPERATIONAL METRICS
A.M. ROUTES
P.M ROUTES
NO. BUSES 11
NO. RTS.
SCHED. LOAD
537
ACTUAL LOAD
406
CAPACITY
847
AVE. SCHED. LOAD/RT.
48.8
AVE. ACTUAL LOAD/RT.
36.9
AVE. TIME/RT.
34.5
AVE. TIME/BUS
AVE. MILES/RT.
8.7
AVE. MILES/BUS
AVE. STOPS/RT.
22.1
SCHED. LOAD/CAPACITY RATIO
63.4%
ACTUAL LOAD/ CAPACITY RATIO
47.9%
NO. BUSES 11
NO. RTS.
SCHED. LOAD
536
ACTUAL LOAD
415
CAPACITY
847
AVE. SCHED. LOAD/RT.
48.7
AVE. ACTUAL LOAD/RT.
37.7
AVE. TIME/RT.
30.6
AVE. TIME/BUS
AVE. MILES/RT.
9.0
AVE. MILES/BUS
AVE. STOPS/RT.
22.0
SCHED. LOAD/CAPACITY RATIO
63.3%
ACTUAL LOAD/ CAPACITY RATIO
49.0%

24. FLORENCE ROCHE ELEMENTARY SCHOOL STUDENT LOADING ANALYSIS A.M. ROUTES
ROUTE NUMBER

25. FLORENCE ROCHE ELEMENTARY SCHOOL ROUTE TIME ANALYSIS A.M. ROUTES
(MIN.)
ROUTE NUMBER

26. OVERALL ROUTE METRICS OVERALL METRICS A.M. ROUTES OVERALL METRICS
P.M. ROUTES
NO. BUSES 18
NO. RTS. 52
SCHED. LOAD
2124
ACTUAL LOAD
1529
CAPACITY
3120
AVE. SCHED. LOAD/RT.
40.8
AVE. ACTUAL LOAD/RT.
29.4
AVE. TIME/RT.
30.5
AVE. TIME/BUS 88
AVE. MILES/RT.
9.5
AVE. MILES/BUS
27.5
AVE. STOPS/RT.
20.1
SCHED. LOAD/CAPACITY RATIO
68.1%
ACTUAL LOAD/ CAPACITY RATIO
49.0%
NO. BUSES 18
NO. RTS. 52
SCHED. LOAD
2125
ACTUAL LOAD
1558
CAPACITY
3120
AVE. SCHED. LOAD/RT.
40.9
AVE. ACTUAL LOAD/RT.
30.0
AVE. TIME/RT.
33.2
AVE. TIME/BUS
95.8
AVE. MILES/RT.
9.5
AVE. MILES/BUS
27.4
AVE. STOPS/RT.
20.0
SCHED. LOAD/CAPACITY RATIO
68.1%
ACTUAL LOAD/ CAPACITY RATIO
49.9%

27. ROUTE TIME and LOADING SUMMARY
FINDING: For Tier 1 routes (High School), the earliest pick up time is currently 6:24 a.m. FINDING: There are currently 2 high school routes which are too long for them to return to do a Tier 2 (Middle School) route. FINDING: For all schools, the route times are generally less than the available tier time. However afternoon routes times are much tighter than in the morning. FINDING: For all schools, both the scheduled and actual student loads are less than the bus capacity. FINDING: A more robust routing software, such as Traversa (Tyler Technologies) would allow the Director of Business and Finance to work smarter relative to more efficient routing and scheduling.

28. BELL SCHEDULE ALTERNATIVES
The following represents the current school start and end times, the typical pick up and drop off times, the length of the school day and the route length with the first pick and last drop off times.
We reviewed a number of options, some of which had been considered and rejected by other school districts. Several of the options considered had little impact on the morning school start times but had a significant impact on the afternoon routes. Because of the different length of the school day between schools, the afternoon available transportation tier time was compressed. Students could not be picked up and dropped off in time to return to the next school on time. Other options resulted in significant student ride times (70+ minutes) and or significantly more buses (4 at an added first year cost of approximately $ 269,330). However, we did identify two options which were feasible:

29. CURRENT SCHOOL SCHEDULES
TIER 1
TIER 2
TIER 3
SCHOOL
HIGH SCHOOL
MIDDLE SCHOOL
ELEMENTARY SCHOOLS
START TIME
7:27
8:08
8:55
DROP OFF TIME
7:05
8:00
8:45
LENGTH/DAY
6'23”
6'17”
6'25”
END TIME
1:50
2:25
3:20
DEPARTURE TIME
1:55
2:30
3:25
ROUTE LENGTH 27 33
FIRST PICK UP
6:24
7:03
8:07
LAST DROP OFF
2:49
3:24
4:09

31. OPTION 1: TWO TIER SYSTEM COMBINING THE ELEMENTARY & HIGH SCHOOLS ROUTES with a HIGH SCHOOL START TIME OF 8:30 A.M. & ELEMENTARY SCHOOLS 7:45 START TIME
A.M. ROUTES
P.M. ROUTES HS SU FR
TOTAL
SCHED
592
287
536
1415
590
289
537
1416
ACTUAL
292
223
415
930
333
206
406
945
CAPACITY
1036
LOAD RATIO
90%
91%
ADD 4 BUSES
75%
76%

32. FINDING-OPTION 1: Given the number of riders for both the Elementary and High School routes (1415 Scheduled and 945 actual), it would take a minimum of 4 additional buses at a first year cost of approximately $ 269,330 to transport them. With either an Elementary or High School drop off, as much as 20 minutes early, students would be on the bus for more than 90 minutes; many of them young children. In the afternoon students would not get home until after 4:15; many of them young children.

33. OPTION 2: TWO TIER SYSTEM COMBINING THE MIDDLE & HIGH SCHOOL ROUTES WITH a HIGH SCHOOL START TIME OF 8:30 A.M. & MIDDLE SCHOOL 7:30 START TIME
A.M. ROUTES
P.M. ROUTES HS MS
TOTAL
SCHED
592
709
1301
590
1299
ACTUAL
292
599
891
333
613
946
CAPACITY
918
LOAD RATIO
97%
103%
ADD 4 BUSES
79%
84%

34. FINDING-OPTION 2: Given the number of riders for both the Middle and High School routes (1301 Scheduled and 946 actual), it would take a minimum of 4 additional buses at a first year cost of approximately $ 269,330 to transport them. With either an Middle or High School drop off, as much as 20 minutes early, students would be on the bus for more than 90 minutes. In the afternoon students would not get home until after 4:15.

35. OPTION 3: THREE TIER SYSTEM ELEMENTARY SCHOOLS 7:45 START TIME: TIER 1 HIGH SCHOOL 8:30 START TIME: TIER 2 MIDDLE SCHOOL 9:00 A.M. START TIME: TIER 3
SCHOOL
TIER 1
ELEMENTARY SCHOOLS
TIER 2
HIGH SCHOOL
TIER 3
MIDDLE SCHOOL
START TIME
7:45
8:30
9:00
DROP OFF TIME
7:30
8:15
8:55
LENGTH/DAY
6'25"
6'23"
6'17"
END TIME
2:10
2:53
3:17
DEPARTURE TIME
2:15
2:58
3:25
ROUTE LENGTH 33 27
FIRST PICK UP
6:46
7:35
8:20
LAST DROP OFF
2:48
3:15
4:10

36. FINDING-OPTION 3: This option is feasible as it will fully utilize all 18 buses for all 3 tiers. However, the Elementary students in Tier 1 with pick-ups starting at 6:46a.m. has historically been unpopular with working parents. In addition, having the elementary age students arriving home before the high school students has also been problematic with working parents who rely on the older children to care for their siblings after school.

37. RECOMMENDATION OPTION 4: THREE TIER SYSTEM
MIDDLE SCHOOL 7:30 A.M. START TIME: TIER 1
HIGH SCHOOL 8:30 START TIME: TIER 2
ELEMENTARY SCHOOLS 9:00 START TIME: TIER 3
SCHOOL
TIER 1
MIDDLE SCHOOLS
TIER 2
HIGH SCHOOL
TIER 3
ELEMENTARY SCHOOLS
START TIME
7:30
8:30
9:00
DROP OFF TIME
7:20
8:20
8:50
LENGTH/DAY
6'17"
6'23"
6'25"
END TIME
1:47
2:53
3:25
DEPARTURE TIME
1:52
2:58
3:30
ROUTE LENGTH 33 27
FIRST PICK UP
6:46
7:45
8:25
LAST DROP OFF
2:40
3:20
4:05

38. FINDING-OPTION 4: This option is feasible as it will fully utilize all 18 buses for all 3 tiers. It is also the least disruptive for the Elementary age students. The Elementary students in Tier 3 with a school start time of 9:00 a.m. has historically been the most popular option with working parents. In this case, the District provides a before school child care program at the Peter Twomey Center. Students can be dropped off as early as 7:00 a.m. In addition, the elementary age students arrive home after the high school students, making child care less problematic for working parents who rely on the older children to care for their siblings after school.

39. FINDING: By utilizing all 18 buses available for all tier times available, the current Middle School routes could be shortened, resulting in faster routes. To start the High School at 8:30 a.m. would require a 7:30 a.m. start time for the Middle School, combined with an early drop off time at the High School. Maintaining the same length of the school day results in the additional 10 minutes required for the afternoon routes to be effective.
No student would be picked up before 6:45 a.m. and the average route times were minutes.
However, a middle school start time of 7:30 a.m. is early and may not be acceptable to working parents. An earlier start time may also be subject to collective bargaining. The Elementary Schools would start 5 minutes later, at 9:00 a.m., but an earlier supervised drop off time (8:30) could be made available to working parents. The Elementary School routes would run 5 minutes later in the afternoon, with the last student drop off at 4:04 p.m.

40. FINDING: By utilizing all 18 buses available for all tier times available, the current High School and Middle School routes could be shortened, resulting in faster routes. The Elementary Schools would start 5 minutes later, at 9:00 a.m., but an earlier supervised drop off time could be made available to parents. The Elementary School routes would run 5 minutes later in the afternoon, with the last student drop off at 4:04 p.m.
RECOMMENDATION: Our recommendation is to revise the Middle School start time to 7:30 a.m., the High School start time to 8:30 a.m. and the Elementary School start times to 9:00 a.m., while maintaining the current lengths of the school day. It is our opinion that this option will be the least disruptive to students, staff and parents.

41. PROGRAM IMPACT The program implications of this recommendation are:
High School start time is 63 minutes later: 8:30 a.m.
Middle School start time at 7:30 a.m. is 38 minutes earlier than the current time of 8:08 a.m.
Elementary School start time is 5 minutes later: 9:00 a.m.
High School, Middle School and the Elementary Schools maintain their current length of school day.
Parents could drop off their elementary school students at 8:30 a.m. for supervised before school activities.
No students are picked up prior to 6:45 a.m. (Current first pick up time is 6:24 a.m.).
Latest Elementary School drop off is 4:15 p.m.
High School students arrive home before Elementary School students for sibling child care.

42. COST IMPACT
The following represents the cost impact of this recommendation:
Utilizing all 18 buses for 3 tiers would reduce the route times, without any significant increased cost.
The cost impact of our recommendation would be the development of a before school (8:30-9:00 a.m.) supervised child care program.
In addition, since the length of the school day is not changing, any collective bargaining issues should be minimal.
However, since the High School end times will be later (2:53), High School athletic schedules will be impacted. In addition, staff and student participation in after school activities, i.e. clubs, etc. could be negatively impacted.

43. RECOMMENDATION
RECOMMENDATION: Given the potential cost and program impact of any bell schedule revision, the School Committee may wish to present their recommendation to the public and all stakeholders prior to any formal final decision. We suggest that any change in bell schedule not be made prior to the school year. This amount of “lead time” will allow all stakeholders to plan and prepare for the schedule changes.

44. QUESTIONS DISCUSSION