Date:    09/20/2000  3:56 PM

Subject: File No. S7-13-00

To SEC members:
     
I am opposed to the proposal that would prohibit firms that audit SEC 
clients from providing non-audit services to their audit clients for the 
following reasons:
     
1) Its too restrictive and would limit the ability of CPA firms to service 
the needs of their clients.
2) It would damage the credibility of the CPA profession as a whole because 
it assumes CPA's would not be able to maintain their independence in these 
situations.
3) It might actually impair the quality of the audits because CPA's would 
lack the extra understanding of their client's business processes they 
obtain by providing these services.
4) It may adversely effect the economic position of some CPA firms by taking 
part of their business away forcing them to raise their services fees which 
in turn negatively effects their clients.
     
Please reconsider the adoption of this proposal.
     
Thank you,
     
     
Karen Watts Kilduff, CPA
Novartis Crop Protection, Inc.