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Great Northern Iron Ore Properties, SEC Correspondence, Dated: May 3, 2005

GREAT NORTHERN IRON ORE PROPERTIES

W-1290 First National Bank Building

332 Minnesota Street

Saint Paul, MN 55101-1361

(651) 224-2385

FAX (651) 224-2387

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

May 3, 2005

Mr. H. Roger Schwall, Assistant Director

U.S. Securities and Exchange Commission

450 Fifth Street, N.W., Stop 04-05

Washington, DC 20549-0405

     Re:
     Great Northern Iron Ore Properties ("Trust")

     SEC Comment Letter dated April 14, 2005, pertaining to the

     Trust's Form 10-K, filed February 25, 2005, File No. 001-00701

Dear Mr. Schwall:

We received, via fax, your comment
letter dated April 14, 2005, requesting supplemental information regarding certain matters
contained within our Form 10-K, as referenced above. On May 3, 2005, we received the same
letter in the U.S. Mail which was postmarked April 28, 2005. Following are your comments
and our responses:

SEC Comment:

Business, page 2

1.      You disclose that your lands contain taconite capable of yielding approximately
332 million tons of iron ore pellets. Supplementally provide:

         •      The basis for this estimate; and
any supporting documents you have.

Great Northern Iron Ore
Properties Response:

The basis for the estimate of
magnetic taconite reserves for our leased lands is determined from a combination of
sources. Our mining engineers estimate reserves by reviewing and utilizing lessee analyses
including diamond drilling results (supporting documents deemed confidential) that include
total iron, magnetic iron, silica and weight recovery of the taconite. The approximate 332
million pellet ton iron ore (taconite) reserve is the aggregate of reserves from a number
of leased properties, with those reserves originally established upon the lease execution
– in some cases 40-plus years ago. Annually (and more frequently if necessary), our
mining engineers reassess the

     Securities and Exchange Commission

Page 2 of 4
     May 3, 2005

properties for any reserve changes
(matters that need revision due to additional diamond drilling results). Usually these
types of changes are relatively minor and infrequent. The primary changes to the overall
reserve estimate are the addition of any new leased properties, the deletion of any
terminated leased properties and the reduction from the reserves to reflect current year
shipments.

     SEC Comment:

     •
     A map that indicates the location and boundaries of all of the lands in which you hold an
interest, and their relationship to the operating mines that are currently paying
royalties.

Great Northern Iron Ore
Properties Response:

Enclosed is a detailed map which
identifies the Trust’s properties, along with the location of the mining companies
and other pertinent landmarks.

     SEC Comment:

     •
     A brief description of the mining operations that mine the land you obtain royalties from,
including discussion of the extent that these mines operate off of your lands, and what
percentage of the mine production has come from your lands for the past several years.

Great Northern Iron Ore
Properties Response:

There are six taconite mining
operations on the iron range in northern Minnesota. The Trust does business with three of
them, those being (1) US Steel — Minntac, (2) US Steel — Keewatin Taconite
(Keetac) and (3) Cleveland Cliffs Inc. (CCI) — Hibbing Taconite Company (Hibtac).
These operations have multiple leases with many different land owners, as well as hold
their own fee interests. Accordingly, they maintain significant freedom to move from
property to property as mining requirements dictate. These requirements include orderly
mine development and ore grading parameters to ensure a proper ore blend to produce a
quality pellet.

The Trust’s taconite pellet
production (also known as shipments) for the past several years, as a percentage of the
mine pellet production (as reported by the mining operations to the State of Minnesota
— Department of Revenue for production tax purposes) for the above three listed
operations, is as follows:

     (1) US Steel - Minntac
     Total Production
     Trust Production
     Percentage

                 Year 2004
     14,327,728
     4,958,405
     35%

                 Year 2003
     13,231,018
     6,153,688
     47%

                 Year 2002
     13,794,178
     3,791,949
     27%

     (2) US Steel - Keetac
     Total Production
     Trust Production
     Percentage

                 Year 2004
       5,343,915
        425,839
       8%

                 Year 2003
       4,376,891
          80,183
       2%

                 Year 2002
       5,463,637
          92,353
       2%

     Securities and Exchange Commission

Page 3 of 4
     May 3, 2005

     (3) Cleveland Cliffs - Hibtac
     Total Production
     Trust Production
     Percentage

                 Year 2004
       8,101,948
     3,782,956
     47%

                 Year 2003
       7,769,999
     3,538,467
     46%

                 Year 2002
       7,408,541
     3,210,144
     43%

SEC Comment:

Exhibit 13

Critical Accounting Policies, page 4

2.      We note under your Critical Accounting Policies disclosure that tonnage
          extracted is agreed upon between Trust and lessee engineers based on various
          engineering methods. Supplementally provide documentation of this process and
          what is involved.

Great Northern Iron Ore
Properties Response:

Our engineers regularly conduct
inspections at the mines, reviewing and assessing data. Methods and parameters used to
determine ore mined from the properties, which are deemed to be “good mining
practices” on the Mesabi Iron Range, primarily include: truck count based on
locations of shovels/loaders that mine (extract) the ore, which truck counts are then
applied to a truck load factor (tons per truck) that is established using State of
Minnesota certified ore scales, volumetric estimates (surveying), blast pattern volumetric
analysis and weight recovery analysis (plant crude/pellet conversion percentages).

Truck counts and truck load factors
are relatively self-explanatory. Daily counts of loaded trucks from the various fee
holdings are prepared by the lessee by shift for our review and analysis. Volumetric
estimates involve surveying and estimation by all the fee owners and the mine
operations’ engineers to agree upon a “volume” of ore that was removed from
each of the fee properties. Ore scales weigh crude ore removed from the mines. Pursuant to
the standards established by State of Minnesota – Weights & Measures, these
scales are frequently tested for accuracy by staff from the mine operations, the State of
Minnesota, Great Northern Iron Ore Properties and other fee owners. Blast pattern
volumetric analysis is primarily estimation from drill-hole data assays. Weight recovery
analysis includes either overall plant weight recovery or specific property (reserve)
weight recovery, the results of which are used to determine pellet production from the
properties.

Due to the variety of engineering
methods used by our lessees, we do not have readily accessible documentation that
conveniently summarizes these methods to determine the tonnage extracted. We do hope,
however, that the explanations described above of the types of engineering methods used to
determine tonnage extracted are adequate for understanding our disclosure.

     _________________

In conclusion, we hope the above
supplemental information satisfactorily answers your inquiries pertaining to certain
disclosures contained in our December 31, 2004, Form 10-K filing. We also acknowledge, as
you require, that we are responsible for the

     Securities and Exchange Commission

Page 4 of 4
     May 3, 2005

adequacy and accuracy of the
disclosure in the Form 10-K filing, that your staff comments or changes to disclosure, if
any, in response to staff comments do not foreclose the Commission from taking any action
with respect to the filing and that the Trust 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. Thank you.

Yours very truly,

/s/ Thomas A. Janochoski

Vice President & Secretary

Chief Financial Officer

enclosure (mailed via U.S. Mail only)

     c:
     Joseph S. Micallef, President and Chief Executive Officer

     Roger W. Staehle

     Robert A. Stein

     John H. Roe III

     Sue Ann Nelson, Fredrikson & Byron

     Robert K. Ranum, Fredrikson & Byron

     Thomas C. Henderson, Ernst & Young LLP