May 23, 2002


Jonathan G. Katz, Secretary
Securities and Exchange Commission 
450 Fifth Street, NW
Washington, DC 20549
Via: rule-comments@sec.gov

Reference - File No. S7-08-02 (Proposed Rule: Acceleration of Periodic Report Filing 
Dates and Disclosure Concerning Website Access to Reports)

Dear Mr. Katz,

Bowater Incorporated is writing to provide its views on the above referenced Securities 
and Exchange Commission (the "Commission") proposed rule.

Decreasing the number of days within which to meet quarterly and annual filing 
requirements would be most burdensome at this time. Therefore, we are opposed to an 
acceleration of the Form 10-Q filing deadline to 30 days from 45 days and opposed 
to an immediate acceleration of the 10-K filing requirements from 90 days to 60 days. 

Bowater issues its earnings releases within 30 days of quarter-end and year-end. 
Bowater's press releases include a consolidated statement of operations and a condensed 
balance sheet and cash flow statement. An earnings release conference call is held the 
day of the press release and all interested parties can listen via internet webcast or 
through a toll free telephone number. In conjunction with the press release, Bowater 
posts to its website a three page financial and operating statistics report.

We believe that an immediate acceleration of the quarterly filing deadlines would create 
a burden on companies and compromises efforts to provide more detail discussion in the 
Management's Discussion and Analysis (MD&A) section, increased financial disclosures 
and in the oversight function. 

Accelerating the filing deadline on a quarterly and annual basis does not automatically 
result in better financial information for investors. Adequate time is required to 
consolidate operations and results, analyze the results, prepare required financial 
statements, footnotes and MD&A, perform required quarterly reviews and annual audits 
with independent auditors and review financial results and filings with a company's 
independent audit committee. Accelerating the filing deadlines, would reduce the amount 
of time management has to analyze results, independent auditors to perform quarterly 
reviews and annual audits and provide management less time to prepare the more extensive 
and detailed disclosures for review by senior management and the audit committee.

In summary, speed of reporting should not take priority over thorough, thoughtful and 
complete reporting and disclosure. Reducing the time to file may run counter to what 
the Commission has been encouraging registrants to do with respect to improving the 
quality of information they provide to investors.  We would request that the Commission 
consider lengthening the transition period so companies could make changes to the 
reporting process to accomplish the acceleration while maintaining the quality of 
reporting.

Sincerely,

/s/ Joseph B. Johnson
Joseph B. Johnson
Director, Accounting and Compliance Reporting
Bowater Incorporated