April 1, 2005


Mail Stop 0409

VIA U.S. MAIL AND FAX (904) 598-3448

Mr. Bruce M. Johnson
Managing Director, Chief Financial Officer and Director
Regency Centers Corporation
121 West Forsyth Street, Suite 200
Jacksonville, Fl  32202

Re:	Regency Centers Corporation
	Form 10-K for the year ended December 31, 2004
	File No. 0-24763

Dear Mr. Johnson:

      We have reviewed your filing and have the following comment.
We have limited our review to only the issue addressed below and
will
make no further review of your document.  As such, all persons who
are responsible for the adequacy and accuracy of the disclosure
are
urged to be certain that they have included all information
required
pursuant to the Securities Exchange Act of 1934.

      We think you should revise your document in response to this
comment in future filings.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In our comment, we ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.


Form 10-K for the year ended December 31, 2004

Real Estate Investments, page F-12
1. Paragraph 7 of SFAS 144 defines impairment as the condition
that
exists when the carrying amount of a long-lived asset exceeds its
fair value.  It further clarifies that a property to be held and
used
is considered to be impaired when its carrying value is not
recoverable and the carrying value exceeds fair value.  This not
indicates that if a held for use property is "permanently
impaired"
you will write it down to fair value.   Please clarify to us if
the
application of this policy has yielded different results than
would
have resulted from the application of paragraph 7 of SFAS 144.  In
addition, please show us how you propose to change the text of
this
note in future filings to clarify the application of paragraph 7
of
SFAS 144.  Please also confirm to us that you will remove the
reference to "permanent impairment" in future filings.

*    *    *    *

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a letter that keys your responses to our comments
and
provides any requested supplemental information.  Detailed
response
letters greatly facilitate our review.  Please file your response
on
EDGAR.  Please understand that we may have additional comments
after
reviewing your response to our comment.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.


In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.

      If you have any questions, you may contact Eric McPhee at
(202)
824-5419 or me at (202) 942-1960.



Sincerely,



      Linda van Doorn
      Senior Assistant Chief Accountant


Regency Centers Corporation
April 1, 2005
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