EXHIBIT 99.15

                    Letter of Arthur Andersen Representation

To the Securities and Exchange Commission:

     We received a letter from Arthur Andersen LLP, dated March 28, 2002,
representing that the audit as of and for the year ended December 31, 2001, was
subject to their quality control system for the U.S. accounting and auditing
practice to provide reasonable assurance that the engagement was conducted in
compliance with professional standards, that there was appropriate continuity of
Arthur Andersen personnel working on the audit and availability of national
office consultation. Availability of personnel at foreign affiliates of Arthur
Andersen is not relevant to this audit.

Very truly yours,

/s/ Ken McBride
Ken McBride
CEO & CFO
March 28, 2002