Subject: File No. 265-23
From: Robert E Joyal
Affiliation: Director, Pemco Aviation Group

March 31, 2006

SOX Section 404 is expected to cost in the range of $1 million during the first year alone which represents a significant burden on the Company and its shareholders.

The Company is now turning the corner after two years of marginal performance and is beginning to enjoy increased revenues from new customers and programs. The Company has been forced to confront the new accounting rules that require expensing of stock options and the continued and significant funding and expense of maintaining its defined benefit plans. Implemetation of SOX Section 404 at this time could well impact our business and shareholders in a negative fashion for extended periods.

Pemco has been active, even before the advent of SOX Section 404, in strengthenilng internal controls. That effort has continued to move forward at a full pace even though the rules for non-accelerated filers did not require immediate action.