From: Hunt, Brian - Legal [Brian.Hunt@IFLYATA.COM]
Sent: Tuesday, November 18, 2003 9:30 AM
To: 'rule-comments@sec.gov'
Subject: (s7-19-03) ATA Holdings Corp.

Dear Gentlemen:

	I am writing to advise you that ATA Holdings Corp. (ATAH) opposes
the SEC proposed rule that would require companies, under certain
circumstances, to include in their proxy materials shareholder nominees for
election as corporate directors.  

	Our initial reaction to the proposed rule is that Sarbanes-Oxley,
SEC rules and the NASDAQ guidelines have all resulted in improved director
accountability to shareholders.  While most of these changes are welcome,
all public corporations are now paying the price for the indiscretions of a
few corporations.  We have already been forced to retain counsel to assist
with the many new proposals and may need to add additional governance staff
in the future.  As an airline struggling in the current economic
environment, we must be ever mindful of increasing costs.  The SEC should
allow time for all of the above-referenced reforms to work before imposing
additional, unproven requirements on issuers.

	Secondly, we do not believe that a contested election is the best
way to select qualified board members.  Like many companies, ATAH has an
independent Nominating and Governance Committee which will now select its
directors.  Shareholder nominees will undoubtedly represent the special
interest agendas of the shareholder that nominated them rather then the
interests of all the shareholders.  

	Finally, we share the concerns and endorse the opinions expressed in
the comment letter submitted to you by the American Society of Corporate
Secretaries on this topic.

						Very truly yours,
						Brian T. Hunt
						General Counsel - ATA
Holdings Corp.