Subject: File No. S7-08-05
From: Roy Centrella, CPA
Affiliation: CAO - Southwest Gas Corporation

October 5, 2005

As a financial statement preparer and large accelerated filer, we would like to comment on the filing deadlines. Southwest Gas Corporation strongly supports the retention of the 40 day filing deadline for 10-Q reports for accelerated filers. We also strongly encourage retention of the 75 day filing deadline for Form 10-K and rejection of the 60 day deadline for any filer.
Consider a typical year end closing schedule. We perform a preliminary close in 10 business days which takes us thru January 13, 2006. From the 13th thru the 22nd, we begin consolidation efforts and prepare schedules and preliminary reports for external auditors to begin year end field work. We also review post year end transactions to ensure nothing comes in which belongs in the prior year. Audit work and preliminary testing of year end controls is primarily performed during the next 3 weeks thru February 10, 2006, although field work technically continues until we file the report. That leaves about two weeks to draft footnotes, MD&A, 10-K text and schedules, certifications, review and signoff of documents by the audit committee, completion of internal control testing and conclusions, all internal reviews, outside audit reviews and signoff, no easy feat, and coordination with proxy material. After that we have several days to coordinate the print effort.
We have been hard pressed to find two more weeks to condense out of the year end process. Going from 90 to 75 days was a significant hurdle, but mainly it required us to be more efficient with our closing and eliminate some of the time we had for reviews. In going from 75 to 60 days, there is no more cushion to draw from. By working harder and making process improvements, we may cut the preliminary close from 10 days to about 8, and weekend days not currently worked add maybe 2-4 more days. The remainder is going to have to come from pre-drafting of the document if you will, resulting in more boiler plate disclosures, and reduction in review time which potentially leads to errors or poorly written disclosures.
For these reasons, we STRONGLY URGE you to leave the
10-K filing deadline at 75 days.