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.
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.
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