Securities and Exchange Commission
|Acceleration of Periodic||) File No. S7-08-02|
|Report Filing Dates and||)|
|Website Access to Reports||)|
Comments of Great Plains Energy Incorporated
Great Plains Energy is the holding company for three wholly owned subsidiaries: Kansas City Power & Light Company, a leading regulated provider of electricity in the Midwest; Great Plains Power Inc., a competitive generator that will sell to the wholesale market; and KLT Inc., an investment company focusing on energy related ventures that are unregulated with high growth potential. On behalf of Great Plains Energy, I appreciate the opportunity to provide our response to the Commission's Proposed Rule: Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports.
Great Plains Energy supports the Commission's emphasis on full disclosure and the belief that clear, accurate and timely information is a prerequisite for efficient market allocation of capital. However, accelerating the filing deadlines for the Forms 10-K and 10-Q will not yield results consistent with these beliefs.
Although companies have experienced advances in communication and information technology over the last 30 years, they have also experienced changes in the business environment. The benefits experienced from technological advances have been more than offset by additional and more complex reporting requirements and business transactions.
Many companies announce their earnings prior to the filing of their quarterly and annual reports. These earnings announcements are generally brief and do not contain many of the disclosures required in the annual and quarterly 10-K and 10-Q filings. The annual and quarterly reports require significant analysis and review that cannot be automated. Reducing the time available to adequately prepare, analyze and review the annual and quarterly 10-K and 10-Q filings will result in a reduction in the quality and completeness of the documents.
Great Plains Energy supports the comments of the Edison Electric Institute and likewise recommends that the Commission not change the filing dates for the Forms 10-K and 10-Q. Acceleration of the filing dates will result in a reduction in the quality and completeness of the filings.