SecProbe.io

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Mail Stop 0308

								May 27, 2005

Mr. Kenneth J. Robinson
Executive Vice President & Chief Financial Officer
Corning Natural Gas Corporation
330 W William Street
P.O. Box 58
Corning, New York 14830

	RE:	Corning Natural Gas Corporation
      Form 10-KSB for the Year Ended September 30, 2004
		Form 10-QSB for the Quarter Ended December 31, 2004
		Form 10-QSB for the Quarter Ended March 31, 2005
      File No. 0-643

Dear Mr. Robinson:

	We have reviewed your response dated April 19, 2005 to our
comment letter dated May 21, 2005 and have the following
additional
comments.  Where indicated, we think you should revise your
documents
in response to these comments.  If you disagree, we will 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 comments, 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 review 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-KSB for the Year Ended September 30, 2004

General

1. Unless otherwise indicated, where a comment below requests
additional disclosures or other revisions to be made, please
include
the additional disclosures and revisions in your future filings.

2. We note that revenues of discontinued operations are included
in
revenues for the 12 month period ended September 30, 2004
disclosed
on the cover page.  Please revise to disclose revenues from
continuing operations.

Item 14 - Principal Accountant Fees and Services
Code of Ethics

3. We note your response to comment number 10 in our letter dated
March 21, 2005.  Please tell us if you intend to satisfy the
disclosure requirement under Item 10 of Form 8-K regarding an
amendment to, or waiver from, a provision of your code of ethics
that
applies to your principal executive officer, principal financial
officer, principal accounting officer or controller, or other
persons
performing similar functions by posting such information on your
Internet website.  If so, please disclose such intention.  Refer
to
Item 406 of Regulation S-B.

Signatures

4. We note your response to comment number 11 in our letter dated
March 21, 2005 and the amendment filed on May 5, 2005.  The report
must also be signed by your chief executive officer, chief
financial
officer and principal accounting officer in the second signature
block.  Please file an amendment containing the appropriate
signatures in the second signature block and indicate each
capacity
in which such persons sign the report.  For example, if your chief
financial officer is also your principal accounting officer,
please
so indicate.  See paragraph 2 of General Instruction C to Form 10-
KSB.

Section 302 Certification

5. We note your response to comment number 12 in our letter dated
March 21, 2005 and the amendment filed on May 5, 2005.  The
certifications contained in the amendment do not conform to Rule
601(b)(31) of Regulation S-B.  Please file an amendment containing
the certifications of each certifying officer exactly as set forth
in
Item 601(b)(31) of Regulation S-B.

Liquidity and Capital Resources

6. We note your response to comment number 15 in our letter dated
March 21, 2005.  Please confirm to us that you intend to disclose
the
effects of noncompliance with the covenants of your lines of
credit
and the existence of cross-default provisions contained in your
debt
agreements in future filings.

Financial Statements
Condensed Consolidated Statements of Income

7. We note your response to comment number 19 in our letter dated
March 21, 2005.  If the only item included in other income is
interest, please consider revising the caption so that it is more
descriptive of the line item.

Consolidated Statements of Cash Flows

8. We note your response to comment number 23 in our letter dated
March 21, 2005.  It appears that the deferred compensation trust
receives proceeds from the sale of marketable securities and
purchases securities in amounts in excess of your contribution.
Please tell us the amounts of proceeds from sale of marketable
securities and disbursements to purchase marketable securities of
the
trust for the years presented, and explain to us why it is
appropriate to net those receipts and disbursements in
consolidating
the accounts of the deferred compensation trust.  Please refer to
paragraph 13 of FAS 95 and EITF 97-14.  Please provide to us a
summary of any other items you have netted in reporting cash
flows.
In addition, please provide to us a summary of the changes in the
balance sheet accounts that are included in the other liabilities
and
deferred credits line item for each year presented and the non-
cash
transactions, if any, that have been excluded from this line item.

9. We note your response to comment number 24 in our letter dated
March 21, 2005.  Please tell us the items included in the gain on
sale of discontinued operations.  In doing so, tell us how you are
recognizing the proceeds on the sale of the assets of the
Appliance
Company that are contingent upon revenue levels attained by the
acquirer.

Notes to Consolidated Financial Statements for the Years Ended
September 30, 2004 and 2003
General

10. We note your response to comment number 28 in our letter dated
March 21, 2005.  Please tell us whether your post-retirement
benefit
plan includes prescription drug benefits.  If so, please tell us:
* whether you adopted FASB Staff Position No. FAS 106-2;
* whether you have concluded that the benefits under your post-
retirement benefit plan are actuarially equivalent to Medicare
Part D
and qualify for the subsidy under the Medicare Prescription Drug,
Improvement and Modernization Act of 2003; and
* how you applied the guidance in the FSP.

Note (2)  Information About Operating Segments

11. We note your response to comment numbers 34, 35 and 36 in our
letter dated March 21, 2005.  The disclosures required by
paragraphs
27, 28 and 32 of SFAS 131 are required in a presentation of
segment
information to the extent specified.  Please confirm to us your
intention to comply with the disclosure requirements of SFAS 131
or
explain your reasons for your intended presentation.

12. We note your response to comment number 37 in our letter dated
March 21, 2005.  Please provide us with your significance test
pursuant to Rule 1-02(w) of Regulation S-X.

Note (4)  Regulatory Assets

13. We note your response to comment number 38 in our letter dated
March 21, 2005.  Please tell us the amounts of each of the
miscellaneous regulatory assets you identified for each year
presented.  Please also tell us whether the regulatory asset
amounts
of $1,250,000 and $800,000 netted in the deferred pension costs
and
other post-retirement benefits liability in your balance sheets
are
intended to represent the same regulatory asset and liability
amounts
of $1,305,575 and $795,750 disclosed in Note 8.  If so, explain
why
there is a difference in rounding for 2004.  In addition, please
tell
us why the change in the regulatory asset related to pension
expense
does not equal the difference between net pension expense
disclosed
in the table in Note 8 and pension expense for ratemaking and
financial statement purposes disclosed in the second paragraph
below
the table.

14. We note your response to our prior comment number 40.  Please
tell us the original entry you made upon the adoption of FAS 109
and
reversal entry you made upon examination of the normalized
accounts
and related reserves for deferred income taxes.  In doing so,
please
tell us the specific deferred tax assets and liabilities and their
amounts that were included in the original entry and why no
adjustments have been made since 1993.  Please also explain to us
why
your existing reserves for deferred income taxes properly reflect
the
future tax liability given the reversal of the original entry.  An
explanation of your accounting process for deferred taxes for
regulated and unregulated operations for periods succeeding the
original entry might be useful to our understanding.

Note (7)  Income Taxes

15. We note your response to comment number 43 in our letter dated
March 21, 2005.  Please provide to us a reconciliation of deferred
income tax expense to deferred income taxes/benefits reflected in
your statements of cash flows for each year presented.

Note (8)  Pension and Other Post-Retirement Benefit Plans

16. We note your response to comment number 46 in our letter dated
March 21, 2005.  Please tell us why net post retirement benefit
expense presented in the reconciliation does not agree to net
periodic benefit cost reflected in the table in the note.  Please
also tell us the other items and their related amounts included in
the deferred pension costs and post-retirement benefits liability
in
your balance sheet for each year presented.  A summary of each
item
and their amounts included in the deferred pension costs and post-
retirement benefits liability on your balance sheets for each year
presented may be useful to our understanding.

Form 10-QSB for the Quarter Ended December 31, 2004

17. We note your response to comment number 54 in our letter dated
March 21, 2005.  It appears that your total revenues including
revenues from non-regulated businesses exceed $25 million for the
last two years.  It does not appear that Item 10(a)(1) of
Regulation
S-B includes a provision for excluding revenues of non-regulated
businesses.  While we accept your "operating approach" income
statement format used in the industry, we do not believe this
changes
the character of revenues from non-regulated business(es).  Under
Item 10(a)(1) of Regulation S-B, an issuer should include all
revenue
on a consolidated basis for purposes of determining the
application
of the definition of a small business issuer.  Furthermore,
revenues
should be based on the annual audited financial statements as
originally filed with the Commission.  Please note that you should
not exclude revenues of operations discontinued after the end of a
reporting period and reclassified in subsequently filed financial
statements in computing the test.  Please refer to Interpretation
4
in Section K of the Manual of Publicly Available Telephone
Interpretations.  If you do not concur with our comment, please
tell
us your basis for excluding revenues of your non-regulated
businesses
including those related to businesses discontinued after the end
of a
reporting period.  Alternatively, please file your quarterly and
annual reports on the appropriate form.

Signatures and Certifications

18. We note your response to comment number 58 in our letter dated
March 21, 2005, the amendment filed on May 5, 2005 and Form 10-QSB
filed on May 13, 2005.  The certifications contained in the
reports
do not conform to Rule 601(b)(31) of Regulation S-B.  Please file
amendments to your quarterly reports containing the certifications
of
each certifying officer exactly as set forth in Item 601(b)(31) of
Regulation S-B.

Form 10-QSB for the Quarter Ended March 31, 2005

Item 1 - Financial Statements,
Notes to Financial Statements
Note D - Segment Overview

19. Please include interim period information for each period for
which an income statement is presented as required by paragraph 33
of
FAS 131.  Please also refer to paragraph 25(d) of FAS 131.

20. We note that you did not include all of the exhibits required
by
Item 601 of Regulation S-B.  Please refer to comment number 57 in
our
letter dated March 21, 2005 and your response to the comment in
your
letter dated April 19, 2005.  Please revise.

Item 2 - Management`s Discussion and Analysis

21. Please refer to comment number 13 in our letter dated March
21,
2005 and your response to the comment in your letter dated April
19,
2005.  Please revise future filings to include a discussion and
analysis of your operations, changes in financial position and
cash
flows for each period presented.  The discussion should also
address
those key variable and other qualitative and quantitative factors
which are necessary to an understanding and evaluation of your
business through the eyes of management.  For example, you should:
* Include an overview that includes the most important matters on
which your executives focus in evaluating your financial condition
and operating performance and provide the context for the
discussion
and analysis of your financial statements;
* Explain and discuss the reasons for known trends, demands,
events,
commitments and uncertainties that have or are reasonably likely
to
have a material affect on your results of operations, financial
condition, liquidity and capital resources;
* Identify and discuss key performance indicators that you use to
manage the business that would be material to investors;
* Include a discussion and an analysis of the business reasons for
material changes in each of the line items in your statements of
income, balance sheets and cash flows and quantify the incremental
impact of each business reason on the overall change in the line
items when there is more than one business reason for a change;
* Include an evaluation of the amounts and certainty of operating
cash flows; and
* Quantify and discuss the extent of dependence on cash flows from
unregulated operations.
Please refer to Item 303(b)(1) of Regulation S-B and SEC Release
33-
8350.  Please explain to us how you intend to modify your
discussion
in the future and the extent to which you agree or disagree with
the
points enumerated above.  You should fully explain the basis for
non-
applicability of any of the above points.

		As appropriate, please amend your filings and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  Please furnish a response letter that
keys your responses to our comments and provides any requested
information.  Detailed response letters greatly facilitate our
review.  Please file your response on EDGAR as a correspondence
file.
Please understand that we may have additional comments after
reviewing your amendments and responses to our comments.

      You may contact Bill Thompson, Staff Accountant, at (202)
551-
3344 or the undersigned at (202) 551-3849 if you have any
questions
regarding these comments.

      Sincerely,

								Jim Allegretto
								Senior Assistant Chief
Accountant
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Mr. Kenneth J. Robinson
Corning Natural Gas Corporation
July 6, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE

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