From: Dr. Richard D. Ruppert
Sent: March 31, 2006
Subject: File No. 4-511

The Audit Committee of PICO Holdings Inc. (PICO-NASDAQ) supports the recommendations of the SEC Advisory Committee on Section 404 of the Sarbanes Oxley Act regarding small companies

The importance of internal controls of any company can not be debated. However,the disproportionate expense visited upon small companies in the spectrum deserves the attention which you have recently recognized. PICO encouragous the SEC to make some accomodation to small companies which reflects that the yield in forcing small companies to comply with Section 404 pales in comparison to the cost.

Richard D. Ruppert MD, Chairman
Carlos C. Campbell
S. Walter Foulkrod.III.Esq.
Audit Committee
PICO Holdings Inc.