Exhibit 99.1


Guidelines for Director Independence

For a director to be deemed "independent," the Board shall affirmatively
determine that the director has no material relationship with GAMCO Investors,
Inc. ("GAMCO") or its affiliates or any member of the senior management of GAMCO
or his or her affiliates. This determination shall be disclosed in the proxy
statement for each annual meeting of GAMCO's shareholders. In making this
determination, the Board shall apply the following standards:

     o    A director who is an employee, or whose immediate family member is an
          executive officer, of GAMCO may not be deemed independent until three
          years after the end of such employment relationship. Employment as an
          interim Chairman or Chief Executive Officer will not disqualify a
          director from being considered independent following that employment.
     o    A director who receives, or whose immediate family member receives,
          more than $100,000 per year in direct compensation from GAMCO, other
          than director and committee fees and pension or other forms of
          deferred compensation for prior service (provided such compensation is
          not contingent in any way on continued service), may not be deemed
          independent until three years after he or she ceases to receive more
          than $100,000 in compensation. Compensation received by a director for
          former service as an interim Chairman or Chief Executive Officer and
          compensation received by an immediate family member for service as a
          non-executive employee of GAMCO will not be considered in determining
          independence under this test.
     o    A director who is affiliated with or employed by, or whose immediate
          family member is affiliated with or employed in a professional
          capacity by, a present or former internal or external auditor of GAMCO
          may not be deemed independent until three years after the end of the
          affiliation or the employment or auditing relationship.
     o    A director who is employed, or whose immediate family member is
          employed, as an executive officer of another company where any of
          GAMCO's current executive officers serve on that company's
          compensation committee may not be deemed independent until three years
          after the end of such service or the employment relationship.
     o    A director who is an executive officer, general partner or employee,
          or whose immediate family member is an executive officer or general
          partner, of an entity that makes payments to, or receives payments
          from, GAMCO for property or services in an amount which, in any single
          fiscal year, exceeds the greater of $1 million or 2% of such other
          entity's consolidated gross revenues, may not be deemed independent
          until three years after falling below that threshold.
     o    Further to the provision above that applies to goods and services
          generally, a director who is, or whose immediate family member is, an
          executive officer, general partner or significant equity holder (i.e.,
          in excess of 10%) of an entity that is a paid provider of professional
          services to GAMCO, any of its affiliates, any executive officer or any
          affiliate of an executive officer, if the payments for such services
          exceed $60,000 (but do not exceed the greater of $1 million or 2% of
          such other entity's consolidated gross revenues) within the preceding
          twelve-month period may not be deemed independent.
     o    A director who is, or whose immediate family member is, affiliated
          with or employed by a tax-exempt entity that receives significant
          contributions (i.e., more than 2% of the annual contributions received
          by the entity or more than $200,000 in a single fiscal year, whichever
          amount is lower) from GAMCO, any of its affiliates, any executive
          officer or any affiliate of an executive officer within the preceding
          twelve-month period may not be deemed independent, unless the
          contribution was approved in advance by the Board of directors.



For purposes of these Guidelines, the terms:

     o    "affiliate" means any consolidated subsidiary of GAMCO and any other
          company or entity that controls, is controlled by or is under common
          control with GAMCO, as evidenced by the power to elect a majority of
          the board of directors or comparable governing body of such entity;
          and
     o    "immediate family" means spouse, parents, children, siblings, mothers-
          and fathers-in-law, sons- and daughters-in-law, brothers- and
          sisters-in-law and anyone (other than employees) sharing a person's
          home, but excluding any person who is no longer an immediate family
          member as a result of legal separation or divorce, or death or
          incapacitation.

The Board shall undertake an annual review of the independence of all
non-employee directors. In advance of the meeting at which this review occurs,
each non-employee director shall be asked to provide the Board with full
information regarding the director's business and other relationships with GAMCO
and its affiliates and with senior management and their affiliates to enable the
Board to evaluate the director's independence.

Directors have an affirmative obligation to inform the Board of any material
changes in their circumstances or relationships that may impact their
designation by the Board as "independent." This obligation includes all business
relationships between, on the one hand directors or members of their immediate
family, and, on the other hand, GAMCO and its affiliates or members of senior
management and their affiliates, whether or not such business relationships are
subject to the approval requirement set forth in the foregoing provision.