<DOCUMENT>
<TYPE>EX-99.77Q2 ITEM 405
<SEQUENCE>3
<FILENAME>peoex77q2.txt
<TEXT>
Sub-Item 77Q-2 for PEO N-SAR:

Section 16(a) Beneficial Ownership Reporting Compliance

Enrique R. Arzac and Kenneth J. Dale, directors for registrant,
each inadvertently failed to file on a timely basis in January
2011 a Form 4 for the receipt of Deferred Stock Units of
registrant pursuant to registrant's 2005 Equity Incentive
Compensation Plan ("DSUs") from their election to defer their
cash retainers for their 2011 Board service for such DSUs. Those
transactions were subsequently reported by each of them on a Form
4 filed on January 31, 2011.
</TEXT>
</DOCUMENT>
