Rural education is characterized by diversity, isolation, and small enrollments. Because of these characteristics, equity in rural school finance is very difficult to achieve. Lacking a workable taxonomy which can accommodate the variations in rural reality, there is neither the information to accurately assess the adequacy of educational programs in small rural schools nor the ability to judge the capacity of rural communities to support adequate educational programs. Although rural schools comprise approximately three-fourths of the nation's school districts and enroll approximately one-third of the student population, this lack of information and inability of the rural constituency to coalesce into a viable political force means rural education has received little, if any, special attention from past school finance reform initiatives. Traditionally, states have acknowledged the "overburden" argument in the funding of rural schools which recognizes the higher per pupil costs related to small size. Recent school reform legislation, mandating additional courses and student and teacher evaluation programs, has added significantly to rural "overburden." Until we can assemble a data base on the real educational needs of rural communities and their ability to support those programs, debate about equity of rural school finance can only proceed at the emotional, political level. (Author/NEC)