We analyse the algebraic constraints of the generalized vielbein in S O(1,
2) x S O(16) invariant d = 11 supergravity, and show that the bosonic degre
es of freedom of d = 11 supergravity, which become the physical ones upon r
eduction to d = 3, can be assembled into an E-8(8)-valued vielbein already
in 11 dimensions. A crucial role in the construction is played by the maxim
al nilpotent commuting subalgebra of E-8(8), of dimension 36, suggesting a
partial unification of general coordinate and tensor gauge transformations.