From: Jaksich, Mark [MCJ@valmont.com]
Sent: Thursday, May 23, 2002 1:01 PM
To: 'Katz, Jonathan'
Subject: File No. S7-08-02

May 22, 2002

Mr. Jonathan Katz, Secretary
Securities & Exchange Commission
450 Fifth Street, NW
Washington, DC 20509

Re: File No. S7-08-02

Dear Mr. Katz,

Valmont Industries, Inc. would like to offer the following comments
regarding the proposals in File No. S7-08-02:

Acceleration of Quarterly and Annual Report Filing Dates
We recognize the need for the public to have complete, timely financial and
business information in order to make informed investing decisions. We also
agree that technological and telecommunications advances in the past 30
years have greatly aided the finance and accounting profession in generating
financial information. However, it is equally true that disclosure
requirements have grown substantially, both in new accounting pronouncements
promulgated by the FASB and reporting disclosure requirements instituted by
the Commission. These additions to the reporting burden over the years have
offset to some extent the  technology-driven productivity gains on the
financial reporting process. In fact, these technological advances have
enabled registrants to continue to abide by the current filing deadlines
despite an undeniably more complex business and accounting environment
today, as compared to 30 years ago.

Regarding the proposal to reduce the filing deadline of Form 10-K, we feel
this proposal is overly burdensome and not reasonable. A year-end closing
process and the disclosure requirements on Form 10-K are far more extensive
than a quarter closing and reporting on Form 10-Q. In addition, like many
companies, our annual report to shareholders contains much of our Form 10-K
requirements and we incorporate this document by reference in Form 10-K. If
the proposed 60 day reporting deadline is codified, much of our annual
report will also have to be disclosed in detail in Form 10-K, which will
cause us additional expense, including duplicative legal and independent
accountant review. We do not feel this additional cost in not in the best
interests of investors nor the registrant. While reducing the filing
deadline for Form 10-K by 30 days is consistent with the Form 10-Q proposal
in percentage terms, the reality is than you are proposing taking more days
out of the filing time on a much more comprehensive and complex document. We
do not believe this is reasonable. A filing deadline of 75 days for Form
10-K would be more reasonable in that it would provide information to
investors on a more timely basis while taking into account the
ever-expanding need for more disclosure and the growing complexity of
financial statement preparation and business in general.

In summary, we respectfully submit that the proposed filing deadlines are
too demanding in light of the current and projected future accounting,
disclosure and audit requirements. The Commission's point regarding
technological advances and productivity improvements is well taken, but
increased disclosure requirements at least partially offset these
improvements. However, we believe some middle ground between the current and
proposed timelines would be reasonable and provide more timely information
to investors. Specifically, a 75 day deadline for Form 10-K, would be
reasonable. An alternative solution could be to require companies in their
earnings releases to provide a somewhat condensed balance sheet and income
statement along with certain key data, such as depreciation and
amortization, capital expenses and segment data. This would allow investors
to perform a greater level of financial analysis at the time of the press
release. 

Website Access to Company Filings	
We support the proposal to provide website access to a registrant's filings
free of charge. However, we believe allowing 24 hours after EDGAR filing
would allow time to deal with unanticipated technical issues, which would be
especially relevant if the accelerated filing deadlines are codified.
Furthermore, allowing 24 hours would allow a registrant to hyperlink
directly into EDGAR, which would be a great way to utilize an existing
reporting medium.  

We appreciate the opportunity to offer our comments are suggestions
regarding these proposals. If you or the staff wish to contact us regarding
this letter, please feel free to contact us.

Respectfully Submitted,


VALMONT INDUSTRIES, INC.
Mark C. Jaksich
Vice-President & Corporate Controller