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PERM for Experts presentation notes

Question:
The PERM regs state that the position must be advertised in a Sunday newspaper, unless the job is in a rural area, with no Sunday newspaper.
Rural is not defined.
Recently we, and other practitioners have seen denials due to the selection of the wrong newspaper. (Rochester MN, while a town of 100,000 people, is surrounded by farms, and has no Sunday paper. Historically, we have always used the "weekend edition" of the local paper for such ads, going back to when the SWA directed recruitment.)

Have you seen this, or a similar problem? If so, how have you dealt with it? Any cases on point? (The decisions I have seen simply say "our research indicates there is a more appropriate newspaper in the area" but do not name the paper, or even state the basis on which the denial rests, i.e. - we don't think you are "rural".) As background, we have seen such a denial for very small communities (population less than 6,000) as well, who are not less than 1.5 - 2 hours commute from any larger town with a Sunday paper

Answer from Jeffrey Devore:
I have not seen any cases on this. However, in my opinion, a town of 100,000 people is not going to be considered rural by any stretch of the imagination. Towns like you describe always get delivery of the major daily/Sunday newspaper, even if it is 100 miles away. I run an ad in the Sunday edition of that newspaper and in the local one as well (pick a day). That way you cover all the basis

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