Date:    09/18/2000  2:16 PM

Subject: S7-13-00

To: SEC
     
From: Thomas R. Newman
     
Baker Newman & Noyes is a regional CPA firm with approximately 150 employees 
headquartered in Portland, Maine. I am the Chairman and Managing Principal of 
this firm. I am writing to you concerning the above referenced rule affecting 
the independence rules under which we operate.
     
We are concerned that the rule would have far reaching impact on the public 
accounting profession and may be adopted in a very compressed time frame without
the benefit of the significant discussion needed within and outside of the 
profession. 
     
I believe the types of consulting services provided to our audit clients have no
effect on our ability to make independent decisions with respect to the audits 
of those clients. Because of the support of our practice provided by the revenue
generated by our consulting practice, it would be difficult to maintain the 
quality of the audit practice without those revenues. Therefore, I believe 
eliminating the consulting portion of our practice would be detrimental to audit
quality.
     
Since there appears to be no empirical evidence that consulting services have 
compromised audit quality or auditor independence, there seems to be little 
reason to adopt a rule that has such a significant impact on the practice of 
public accounting.
     
Therefore, we would ask you not to adopt the rule.
     
Sincerely,
     
Thomas R. Newman