STEEL                                           Steel Hector & Davis LLP

HECTOR                                          200 South Biscayne Boulevard

& DAVIS                                         Miami, Florida 33131-2398

                                                305.577.7000

                                                305.577.7001 Fax

                                                www.steelhector.com





                                         June 4, 2004





FPL Group, Inc.

FPL Group Capital Inc

FPL Group Capital Trust II

FPL Group Capital Trust III

FPL Group Trust I

FPL Group Trust II

700 Universe Boulevard

Juno Beach, Florida 33408



Ladies and Gentlemen:



     As counsel for FPL Group, Inc., a Florida corporation ("FPL Group"), FPL

Group Capital Inc, a Florida corporation ("FPL Group Capital"), FPL Group

Capital Trust II, a Delaware statutory trust, FPL Group Capital Trust III, a

Delaware statutory trust, FPL Group Trust I, a Delaware statutory trust, and FPL

Group Trust II, a Delaware statutory trust (together with FPL Group Capital

Trust II, FPL Group Capital Trust III and FPL Group Trust I, the "Trusts"), we

have participated in the preparation of a joint registration statement on Form

S-3 to be filed on or about the date hereof with the Securities and Exchange

Commission ("Commission") under the Securities Act of 1933, as amended

("Securities Act"), in connection with the registration by:



     (a) FPL Group of up to a total of $1,400,000,000 of (i) its guarantee

relating to FPL Group Capital's Debt Securities (as defined below) ("Debt

Securities Guarantee"); (ii) its guarantee of the FPL Group Capital Junior

Subordinated Debentures (as defined below) ("Subordinated Debenture Guarantee");

(iii) its junior subordinated debentures ("FPL Group Junior Subordinated

Debentures"); (iv) its guarantee of Preferred Trust Securities (as defined

below) of the Trusts ("Preferred Trust Securities Guarantee"); (v) shares of its

common stock, $.01 par value ("Common Stock"), including the preferred share

purchase rights ("Rights") attached thereto (collectively, "Shares"); (vi)

shares of its serial preferred stock, $.01 par value ("FPL Group Preferred

Stock"); (vii) contracts to purchase Shares or other agreements or instruments

requiring it to sell Shares (collectively, "Stock Purchase Contracts"); and

(viii) units, each representing ownership of a Stock Purchase Contract and debt

securities of FPL Group Capital (including, but not limited to, Debt

Securities), preferred trust securities of one or more FPL Group subsidiary

trusts or other subsidiary entities (including, but not limited to, Preferred

Trust Securities), or debt securities of third parties, including, but not

limited to, U.S. Treasury securities ("Stock Purchase Units") and (ix) its

guarantee ("Preferred Stock Guarantee") of FPL Group Capital Preferred Stock (as

defined below),



     (b) FPL Group Capital of up to a total of $1,400,000,000 of its (i)

unsecured debt securities ("Debt Securities"); (ii) junior subordinated

debentures ("FPL Group Capital Junior Subordinated Debentures"); and (iii)

shares of its preferred stock, $.01 par value ("FPL Group Capital Preferred

Stock"), and



     (c) the Trusts of up to a total of $1,400,000,000 of their preferred trust

securities ("Preferred Trust Securities").



     In connection therewith, we have reviewed such documents and records as we

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