From: Don Hatchel [Don.Hatchel@paccar.com]
Sent: Thursday, May 23, 2002 5:55 PM
To: 'rule-comments@sec.gov'
Subject: File No. S7-08-02

PACCAR Inc
777 - 106th Avenue NE
Bellevue, WA 98004
(425) 468-7400

May 23, 2002

Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-6009

Subject: Proposed Acceleration of Periodic Report Filing Dates
(File No. S7-08-02)

Dear Mr. Katz:

PACCAR submits the following comments on the Commission's proposal to reduce
by one-third the amount of time allowed to prepare a company's Form 10-Q and
Form 10-K.  PACCAR is a multinational manufacturer of commercial trucks sold
under the Kenworth, Peterbilt, DAF and Foden nameplates.  The Company also
manufactures industrial winches and provides financial services to support
the sale of its products. The Company has world-wide assets of approximately
$8 billion.

In attaining the Commission's objective of making periodic filings more
timely, a consequence of the proposal is the reduction in the preparation
time for the filer.  We agree that an efficient market must have timely
financial information, however the preparation of useful and meaningful
financial information requires the adequate investment of time and
resources.

While the consolidation of the primary financial statements has largely been
automated over the years, a great deal of effort is still required to
prepare the required footnote information. The bulk of this data is gathered
once annually and is not contained in any automated system within the
Company and therefor the collection and consolidation of this information is
not a routine process. 

The Commission states that the filing deadlines for quarterly and annual
reports have not changed in over 30 years. As others who have already
provided you comments have stated, in this same time period there have been
literally hundreds of new pronouncements and rulings on required disclosures
that have been issued by the FASB, EITF, AICPA and the SEC.  By way of
comparison, PACCAR's financial statements in its 1972 Annual Report totaled
8 pages. In 2001, the financial section ran 26 pages, a 325% increase.  Over
this same time period, the amount of resources the Company has been required
to dedicate to this activity has grown significantly.  While PACCAR has
certainly also grown in size and geographic scope over this same time
period, it remains now as it was 30 years ago, an industrial manufacturer
whose primary business is the building of commercial trucks.  Thus, while
the filing deadline may not have changed over the last 30 years, little else
about the reporting process has remained the same.

The increase in the number and complexity of footnote disclosures has
increased the time required for auditors and audit committees to fulfill
their oversight responsibilities to conduct a thorough, meaningful and
thoughtful review.  Compressing the review schedule will jeopardize efforts
to improve oversight and the quality of reporting.  PACCAR incorporates the
Annual Report by reference into its Form 10-K filing, significantly reducing
our production costs and review time since this allows us to publish our
financial statements only once and not duplicate them in a second
publication.  An acceleration of the deadline to 60 days after the end of
the year would require us to publish a second set of financial statements
for inclusion in our Form 10-K.  This is because we would be unable to
accelerate the production of our annual report sufficiently to allow us to
continue to incorporate them by reference.  

As a result of the increased costs and risk of reduced quality of reported
financial information, PACCAR does not support the acceleration of the
filing deadlines, particularly the Annual Form 10-K requirement to 60 days.

Thank you for the opportunity to express our views on this issue. 


G. D. Hatchel
Vice President and Controller
PACCAR Inc