SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
Mail Stop 7010
March 30, 2007

By US Mail and Facsimile

Mr. Russell M. Gifford
Chief Financial Officer
Barnwell Industries, Inc.
1100 Alakea Street, Suite 2900
Honolulu, HA  96813

Re: Barnwell Industries, Inc.
 Form 10-K for the Fiscal Year Ended September 30, 2006
 Filed December 21, 2006
 File No. 1-5103

Dear Mr. Gifford:

We have limited our review of your filings to those issues we have addressed in
our comments.  Where indicated, we think you should revise your documents in response
to these comments.  If you disagree, we w ill consider your explanation as to why our
comment is inapplicable or a revision is unnecessary.  Please be as detailed as necessary
in your explanation.  In some of our comme nts, we may ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.

Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Mr. Russell M. Gifford
Barnwell Industries, Inc.
March 30, 2007 Page 2
Form 10-K for the fiscal year ended September 30, 2006

Item 1. Business, page 4

Estimated Future Net Revenues, page 13

1. We note your disclosure of the table cal culating the present value of estimated
future net revenues as of September 30, 2006.  Further, we note that you have
calculated net revenues using current sales prices and costs, after deducting all
royalties, operating costs, future estimated capital expenditures, and income taxes.  This measure does not appear to -differ from the standardized measure that you
have calculated and presente d in accordance with SFAS 69.    As such, please
revise the label to state st andardized measure of estimated discounted future net
cash flows.

Management’s Discussion and Analysis and Financial Condition and Results of
Operations, page 34

Critical Accounting Policies and Estimates, page 34

2. We note that you have identified many ar eas of accounting that you regard as
critical, due to the significant level of  judgment required to determine various
assumptions underpinning their applica tion, and which under different conditions,
could lead to “material differences” in your financial statements.  However, the disclosures that you provide appear to be  essentially the same as the accounting
policies utilized, rather than any specif ic uncertainties underlying your estimates.
In other words, not all of the critical accounting policies that you disclose appear
to have critical judgment and estimati on attributes, and for those that do, the
disclosures do not sufficientl y address such attributes.

Please revise your disclosures to addre ss the material implications of the
uncertainties that are associated with  the methods, assumptions and estimates
underlying your critical a ccounting estimates.  Specifi cally, you should provide
the following:

(a)        An analysis of the uncertain ties involved in applyi ng the principle and the
variability that is reasonably like ly to result from its application.

(b)        An analysis of how you a rrived at the measure and how accurate the
estimate or underlying assumptions have been in the past.

(c)        An analysis of your specifi c sensitivity to change, based on outcomes that
are reasonably likely to occur and have a material effect.

Please refer to FRC Section 501.14 for further guidance.

Mr. Russell M. Gifford
Barnwell Industries, Inc.
March 30, 2007 Page 3

Item 7A.  Quantitative and Qualita tive Disclosures about Market Risk

3. We note that you provide qualita tive discussion about market  risk as it pertains to
commodity price risk, interest rate risk  and foreign currency exchange risk.
However, it does not appear that you ha ve provided the quantitative disclosures
required by Item 305 of Re gulation S-K.  Please e xpand your disclosure to
provide this information using at least one of the three acceptable disclosure
alternatives outlined in It em 305 of Regulation S-K.

Financial Statements

Statements of Cash Flows, page 61

4. We note that you present cash proceeds from sale of interest in leasehold land and development rights as an investing activity on your consolidated statements of
cash flows.  Since you present the sale of in terest in leasehold land and the sale of
development rights as operating revenues on your statements of operations as well as you identify your real esta te investing activities as a reportable segment, it is
unclear to us why you do not consider thes e cash flows from ope rating activities.
Please explain to us in detail your basis for presenting these cash flows as an
investing activity.
Note 2 – Significant Accounting Policies, page 65

Oil and Gas Properties, page 65

5. We note that a majority of your proved rese rves are gas.  As such, please disclose
your method of accounting for gas imbalances and to the extent significant, the
amount of any imbalance in terms of units and value.  Refer to EITF 90-22 for further guidance.

Investment in Land and Revenue Recognition, page 66

6. We note your disclosure in which you e xplain that you account for your sales of
development rights under option and leas ehold land interests pursuant to the
provisions of SFAS 66.  This accounting st andard provides extensive guidance on
how to identify criteria to be used to determine when and how profit is recognized
on real estate sales.  Due to the comple xity of this guidance, please expand your
accounting policy disclosure to indicate the specific method you use to recognize
revenue including the criteria that has been met to support your profit recognition methodology.

Mr. Russell M. Gifford
Barnwell Industries, Inc.
March 30, 2007 Page 4
As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e us with a response.  You may wish to
provide us with marked copies of the amendm ent to expedite our review.  Please furnish
a cover letter with your amendment that keys your responses to our comments and provides any requested information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.

  We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

 In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:

‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

 You may contact Nasreen Mohammed at (202) 551-3773 or Jenifer Gallagher at
(202) 551-3706 if you have questions regard ing comments on the financial statements
and related matters.   Please contact me at (202) 551-3686 with any other questions.

        S i n c e r e l y ,

        K a r l  H i l l e r
        B r a n c h  C h i e f