May 20, 2002
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20509

Re: File No. S7-08-02

Acceleration of Periodic Report Filing Dates and Disclosure Concerning
Website Access to Reports

Dear Mr. Katz:

Progress Energy, Inc. ("Progress Energy") is a registered public utility holding company with annual operating revenues of approximately $8.5 billion and assets of approximately $20.7 billion. As such, we are interested in the proposals in File No. S7-08-02 and submit our comments for consideration.

Acceleration of Quarterly and Annual Report Due Dates

Progress Energy is very concerned with the proposed acceleration of quarterly and annual report due dates. While we acknowledge that technological advances have created time efficiencies in report preparation in comparison to the past, we believe other factors have contributed to substantially more effort to prepare and review the reports. In summary, Progress Energy believes that the current due dates remain reasonable given the quantity and quality of information that should be provided in these reports.

We believe specific factors such as the following should be considered with regard to the proposed change.

• Accounting and disclosure requirements have become increasingly more complex, which results in increased time to analyze results, prepare disclosures and adequately review.
  

• There has been an increasing emphasis on the analysis of data in order to make management's discussion and analysis more useful. We believe that the quality of analysis could be negatively affected by the proposed dramatic changes in due dates.

• Much work with regard to the filings cannot begin until after the closing of the books and preparation of financial statements, which typically requires 10 to 15 business days after the end of the applicable period.

• The typical activities leading to Form 10-K filing include (similar activities for Form 10-Q):

  • Closing of books and preparation of financial statements

  • Preparation of draft report, including necessary analyses and solicitation of information from personnel throughout the company

  • First draft of report submitted to financial and operations personnel for review

  • Incorporate comments received and issue second draft of report submitted to financial and operations personnel and independent audit firm for review

  • Incorporate comments received and issue third draft to senior management, board audit committee and independent audit firm for review

  • Incorporate comments received and submit to board of directors for approval

As indicated above, a substantial amount of time is invested in review to help ensure the quality of the information being reported. We believe the proposed changes in due dates would not allow adequate time for that extensive review process.

• Many entities have multiple registrants, including Progress Energy with four (Progress Energy, Carolina Power & Light Company, Florida Progress Corporation and Florida Power Corporation). Therefore, the activities discussed above are being performed for multiple registrants, with much of the preparation and review by the same groups. We believe that reducing the due dates will unduly strain these resources and affect the quality of the filings produced.

In our opinion, factors such as those outlined above clearly indicate that the proposed due dates are not reasonable and should not be adopted.

Website Access to Information

Progress Energy supports this proposal, with the following caveat. We recommend that the wording of the availability of website information be changed from "and in any event on the same day as" to "and in any event within 24 hours". This change in wording will better accommodate the fact that filings might occur at various times throughout a day.

We appreciate the opportunity to provide our comments on this important issue.

Yours very truly, Robert Bazermore

RHB/mdf