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                              September 23, 2021

       John P. Sauerland
       Vice President and Chief Financial Officer
       The Progressive Corporation
       6300 Wilson Mills Road
       Mayfield Village, Ohio 44143

                                                        Re: The Progressive
Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed March 1, 2021
                                                            File No. 001-09518

       Dear Mr. Sauerland:

              We have reviewed your filing and have the following comments. In
some of our
       comments, we may ask you to provide us with information so we may better
understand your
       disclosure.

              Please respond to these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year Ended December 31, 2020

       Item 1A. Risk Factors, page 12

   1.                                                   Disclose any material
litigation risks related to climate change and the potential impact to
                                                        the company.
       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of
       Operations, page 29

   2.                                                   There have been
significant developments in federal and state legislation and regulation
                                                        and international
accords regarding climate change. We note that you have not discussed
                                                        the impact of pending
or existing climate change-related legislation, regulations, and
                                                        international accords
in your SEC filing. Please revise your disclosure to identify material
                                                        existing climate
change-related legislation, regulations, and international accords and any
                                                        material effect on your
business, financial condition, and results of operations.
 John P. Sauerland
The Progressive Corporation
September 23, 2021
Page 2
3.       To the extent material, please discuss capital expenditures for
climate-related projects and
         quantify those expenditures. We note that you provided more expansive
disclosure in
         your CSR report regarding building infrastructure with automated
energy-efficient
         equipment and investment in facilities, equipment, and company
vehicles that are
         increasingly energy and fuel efficient.
4.       If material, discuss the significant physical effects of climate
change on your operations
         and results. This disclosure may include quantification of material
weather-related
         damages to your property or operations and any weather-related impacts
on the cost or
         availability of reinsurance.
5.       Disclose the material effects of transition risks related to climate
change that may affect
         your business, financial condition, and results of operations, such as
policy and regulatory
         changes that could impose operational and compliance burdens, market
trends that may
         alter business opportunities, credit risks, or technological changes.
6.       Quantify any material increased compliance costs related to climate
change.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Todd Schiffman at 202-551-3491 or Erin Purnell at
202-551-3454 if
you have questions regarding these comments.



FirstName LastNameJohn P. Sauerland                            Sincerely,
Comapany NameThe Progressive Corporation
                                                               Division of
Corporation Finance
September 23, 2021 Page 2                                      Office of
Finance
FirstName LastName