From: Bates, Jim [jbates@midcoast-aviation.com]
Sent: Monday, December 09, 2002 9:03 AM
To: 'rule-comments@sec.gov'
Subject: File No. S7-49-02

Dear Sirs/Madams;
"prohibit an accounting firm from auditing an issuer's financial statements
if certain members of the issuer's management team had been members of the
accounting firm's audit engagement team within the one-year period preceding
the commencement of audit procedures"

I believe it is a restraint of trade to prohibit CPA's from pursuing
employment with whatever firm they desire.  This one year prohibition will
not serve to make companies more independent, rather it will unfairly limit
a CPA's ability to pursue his profession in the private industry sector.

Jim Bates
V.P. CFO
Midcoast Aviation, Inc.
314-378-7403 Voice
618-337-3001 Fax