A. Scholarship and Grant-Making Activities 

By conducting the activities set forth in response to this Part IV, the Jamison Transportation Foundation (“JTF”) aims to bridge the opportunity gap for underrepresented people and veterans in transportation professions, including but not limited to engineering, aviation, and aerospace fields. JTF will identify potential recipients from those individuals who apply for scholarship funds and from those who are identified by educational institutions,

teachers, or others, as worthy of consideration. If so identified, any potential recipient must apply for and be considered for the scholarship funds available at that time. As part of the application process, individuals must demonstrate a track record of hard work, academic excellence,

personal responsibility, and a minimum grade point average of 3.0. Along with the application, potential recipients must participate in an interview as well as submit transcripts and an essay on the individual’s leadership and professional development.

To further detail the grant-making and other funding processes, on an annual basis, JTF will determine the values of scholarships and grants it will fund, pursuant to any gift agreements. Grantee organizations will be selected based on tax-exempt status, alignment with JTF’s mission

and commitment to championing opportunities for underrepresented groups and young adults to access education, professional development, and leadership opportunities. Organizations must submit funding proposals specifying the responsibilities of both JTF and the grantee, and JTF

will conduct a thorough evaluation of each proposal. JTF and the grantee organizations will each implement autonomous and streamlined protocol for publicizing its own programs, identifying prospective students and participants, soliciting recipient applications, and awarding funds.

Where scholarship programs are administered by grantee organizations rather than JTF itself,  JTF will review scholarship applications and submit recipient recommendations to the grantee organization. To ensure distributions are used for the intended purposes, grantees will submit

reports on the use of funds. JTF will maintain records and actively monitor all recipients. Currently, JTF intends to undertake the bulk of its activities through scholarships, grants, and collaborations with other organizations. However, JTF may also operate direct programs to advance specific areas of its work and charitable purposes. JTF’s board of directors will initially funded its activities, while cultivating fundraising from other funders and stakeholders.

B. Individuals and Committees Conducting Organizational Activities

JTF’s board and/or independent selection committee will make all funding decisions based on objective determinations of need and/or merit and will determine grantee organizations based on tax-exempt status under the Internal Revenue Code (“Code”) and alignment with JTF’s mission. Both the board and any committee or entity making such decisions, will adhere to procedures ensuring that all criteria are consistently applied to each applicant and grantee organization. The directors and committee members who are not in a position to exercise any influence over the affairs of the grantee organizations, the educational institutions the applicants may attend, the individual recipients, or any related parties thereto, shall make all determinations about grant-making and other funding. The individual recipients shall not be related by blood or marriage to any of the JTF directors, and assistance will not be provided to or for the benefit of any pre-selected individuals, nor as a means of compensation or consideration for contractual obligations. JTF is neither affiliated with nor in any way controlled by any grantee organization or educational institution that may admit students in receipt of JTF scholarships. JTF may also hire staff to carry out its activities, which will be led by the President and overseen by the board. The board will be a diverse group of funders, community stakeholders, educators, and other experts.  

C. Furtherance of Charitable and Educational Exempt Purposes

JTF will provide aid and funding that allows individuals to begin or continue educational or vocational training at colleges, universities, and trade schools and supports tax-exempt organizations in facilitating such activities; therefore, JTF serves exclusively charitable and educational purposes. Scholarships will be granted based on need as specifically permitted pursuant to Rev. Rul. 66–103, 1966–1 C.B. 134, and/or merit as permitted pursuant to Rev. Rul.69–257, 1969–1 C.B. 151. See Rev. Rul. 69–257, 1969–1 C.B. 151; Rev. Rul. 66–103, 1966–1C.B. 134; Rev. Rul. 56–403, 1956–2 C.B. 307; Rev. Rul. 67–367, 1967–2 C.B. 188; Rev. Rul. 63–220, 1963–2 C.B. 208; and Rev. Rul. 61–87, 1961–1 C.B. 191 (nonprofit organizations that award scholarships based on scholastic ability, without regard to financial need, may qualify for exemption under the Code). Additional assistance may include provisions for books or supplies, as permitted in Rev. Rul. 64–274, 1964–2 C.B. 141, and Rev. Rul. 76–336, 1972–2 C.B. 143. 

JTF activities will serve grantee organizations and a charitable class of individuals that is indefinite and open-ended, because the financial need and merit-based determinations necessary for assistance cannot be pre-determined, and it is not possible to individually identify those from the large class who may fall within these categories in the future. The purposes and activities of JTF are more broad than other exempt entities established to provide educational opportunities to a more limited, narrow class of potential recipients. See Rev. Rul. 56–403, 1956–2 C.B. 307 (a foundation awarding scholarships solely to undergraduate members of a designated fraternity could be an exempt charitable and educational organization). Recipients must only reside in the United States to qualify; therefore, the benefits will be far-reaching. The broader community and economy will also benefit through greater productivity and private funding for educational undertakings. JTF’s exemption should be permitted inasmuch as there is no specific designation of eligible funding recipients, and the purposes of JTF are not so personal, private, or selfish in nature as to lack the elements of public usefulness and benefit required of organizations qualifying for exemption under the Code. 

JAMISON TRANSPORTATION FOUNDATION

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