From: K_M_Davis@fpl.com Sent: Thursday, May 23, 2002 4:03 PM To: rule-comments@sec.gov Cc: Daisy_Jacobs@fpl.com Subject: File No. S7-08-02 Dear Mr. Katz: FPL Group appreciates the opportunity to respond to the Securities and Exchange Commission's proposed rule regarding acceleration of period report filing dates and disclosure concerning website access to reports. FPL Group is a public utility holding company. Its operations are primarily conducted through Florida Power & Light Company, one of the largest investor-owned electric utility companies in the nation, serving about half the population of Florida. The Company also owns and operates independent power facilities through its unregulated power generation subsidiary, FPL Energy, LLC. Acceleration of Form 10-K and Form 10-Q Filings FPL Group strongly opposes the proposal to shorten filing deadlines. While we understand that filing deadlines have not changed in the past 30 years and that technology improvements have made preparation and distribution of the document easier, these efficiencies have been more than offset by the increase in the complexity of the business and in disclosure requirements. The time spent preparing periodic filings includes time required to understand and analyze financial information, comply with the various and increasing disclosure requirements, and allow for thorough review by our audit committee, independent auditor and legal counsel. Accelerating the filing requirements would allow less time to thoroughly analyze financial statements to ensure that the proper disclosures are made and would allow less time for the reviews that are critical to ensuring a quality filing. We believe that this proposal conflicts with the Commission's desire to provide meaningful, complete and transparent financial reporting to investors and strongly urge the Commission to not change the current filing deadlines. Website Filing Requirements FPL Group supports the requirement that SEC filings be made available on a registrant's website as soon as reasonably practicable after filing, and provides such access today on our website. We agree that a key benefit of the Internet is that registrants can make information available to many investors on a timely basis. We believe however, that the requirement should be to make the filings available within one business day after filing, rather than within the same day as proposed. This time is needed to prepare the file to be posted to the website. We also believe that the SEC should allow immediate access to registrant filings via EDGAR instead of the 24-48 hour delay that exists today. The SEC's website is the most logical place for investors to obtain all documents filed rather than having to go from company website to company website. Respectfully submitted, K. Michael Davis Controller and Chief Accounting Officer