Yes. Indirect appeals (examples given) have the same effect as direct appeals and would violate .180, depending upon the context. Board quoted general rule established in AO95 - No. 18. In addition, in dealing with bills which become ballot measures, newsletter authors are advised to make a choice between (1) encouraging voting and including only a balanced, objective description of the measure or (2) including direct comments on the merits of the proposal as a bill, with no reference to voting except to note that the bill is now a ballot measure.