Exhibit 5(a).1.


                    [LETTERHEAD OF STEEL HECTOR & DAVIS LLP]


                                          April 11, 2003

FPL Group, Inc.
FPL Group Capital Inc
700 Universe Boulevard
Juno Beach, Florida 33408

Ladies and Gentlemen:

     As counsel for FPL Group, Inc., a Florida corporation ("FPL Group") and FPL
Group Capital Inc, a Florida corporation ("FPL Group Capital"), we have
participated in the preparation of or reviewed (1) Registration Statement Nos.
333-85218 and 333-85218-01 effective on April 24, 2002, which registration
statement was filed jointly by FPL Group and FPL Group Capital with the
Securities and Exchange Commission (the "Commission") under the Securities Act
of 1933, as amended (the "Securities Act"); (2) Registration Statement Nos.
333-102173, 333-102173-01, 333-102173-02 and 333-102173-03, as amended, which
became effective on April 3, 2003, which registration statement was filed
jointly by FPL Group, FPL Group Capital, FPL Group Capital Trust I, and FPL
Group Capital Trust II with the Commission under the Securities Act; (3) the
combined prospectus dated April 3, 2003 forming a part of Registration Statement
Nos. 333-102173, 333-102173-01, 333-102173-02 and 333-102173-03, as supplemented
by a prospectus supplement dated April 8, 2003 relating to $500,000,000
principal amount of 3 1/4% Debentures, Series due April 11, 2006 (the
"Debentures"), issued under the Indenture (for Unsecured Debt Securities), dated
as of June 1, 1999 (the "Indenture"), from FPL Group Capital to The Bank of New
York, as Trustee ("Trustee"), which Debentures are absolutely, irrevocably and
unconditionally guaranteed (the "Guarantee") by FPL Group pursuant to that
Guarantee Agreement, dated as of June 1, 1999 (the "Guarantee Agreement"), from
FPL Group to The Bank of New York, as Guarantee Trustee, both such prospectus
and prospectus supplement filed pursuant to Rule 424(b) under the Securities
Act; (4) the Indenture; (5) the Guarantee Agreement; (6) the corporate
proceedings of FPL Group Capital with respect to the Registration Statement and
the Debentures; (7) the corporate proceedings of FPL Group with respect to the
Registration Statement and the Guarantee; and (8) such other corporate records,
certificates and other documents (including a receipt executed on behalf of FPL
Group Capital acknowledging receipt of the purchase price for the Debentures)
and such questions of law as we have considered necessary or appropriate for the
purposes of this opinion.





FPL Group, Inc.
April 11, 2003
Page 2


     Based on the foregoing, we are of the opinion that the Debentures and the
Guarantee are legally issued, valid, and binding obligations of FPL Group
Capital and FPL Group, respectively, except as limited or affected by
bankruptcy, insolvency, reorganization, receivership, moratorium or other laws
affecting creditors' rights and remedies generally and general principles of
equity.

     In rendering the foregoing opinion, we have assumed that the certificates
representing the Debentures will conform to specimens examined by us and that
the Debentures will be duly authenticated by the Trustee under the Indenture and
that the signatures on all documents examined by us are genuine, assumptions
which we have not independently verified.

     We hereby consent to the filing of this opinion as an exhibit to
Post-Effective Amendment No. 1 to Registration Statement Nos. 333-102173,
333-102173-01, 333-102173-02 and 333-102173-03.

     We are members of the Florida Bar and this opinion is limited to the laws
of the State of Florida and the federal laws of the United States insofar as
they bear on the matters covered hereby. As to all matters of New York law, we
have relied, with your consent, upon the opinion of even date herewith rendered
to you by Thelen Reid & Priest LLP, New York, New York. As to all matters of
Florida law, Thelen Reid & Priest LLP is authorized to rely upon this opinion as
if it were addressed to it.

                                          Very truly yours,


                                          /s/ STEEL HECTOR & DAVIS LLP

                                          STEEL HECTOR & DAVIS LLP