The Great Atlantic & Pacific Tea Company, Inc.
2 Paragon Drive, Montvale, New Jersey 07645
Phone: 201-571-8714 Fax: 201-571-8715

Mitchell P. Goldstein
Senior Vice President
Chief Financial Officer

May 17, 2002

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

Dear Mr. Katz,

After analyzing and reviewing the implications of the Securities and Exchange Commission's File No. S7-08-02 "Acceleration of Periodic Report Filing Dates and Disclosure Concerning Website Access to Reports," The Great Atlantic & Pacific Tea Company ("A&P") feels compelled to respond with its concerns. A&P believes that it will be extremely difficult to meet accelerated reporting deadlines in the timeframe proposed by the Commission.

We are all well aware of the failure of Enron and its causes. We also realize the pressure put on the Commission to ensure a failure of this magnitude never again occurs. A&P views some of the proposals and discussions as progressive and some as regressive. It is plausible, for example, that requiring auditor independence by limiting the ability of external auditors to perform non-audit services for an audit client would be a safeguard to the investing community. However, decreasing the amount of time a registrant has to file its Form 10-K and Form 10-Q would be detrimental for several reasons:

While A&P strongly supports the Commission's motivation to improve financial reporting, it believes decreasing filing deadlines would not accomplish that goal and would ultimately increase costs, reduce external auditor accuracy and decrease earnings for its stockholders.

The following are excerpts from the official proposal by the Commission that A&P believes carry tremendous weight...

"In establishing the appropriate timeframes for filing periodic reports, however, we must balance the market's need for information with the time companies need to prepare that information without undue burden."

"...benefits derived from technological advances over the past 30 years have been offset by additional and more complex reporting requirements."

Please be mindful of the additional financial burden and increasing complexity of reporting requirements that stand in the way of all registrants.


Mitchell P. Goldstein
Senior Vice President
Chief Financial Officer

Brenda M. Galgano
Vice President
Corporate Controller