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MMR Response Letter Dated 5-19-05

[McMoRan
Letterhead]

May 19,
2005

      Securities
      and Exchange Commission

      450
      Fifth Street, N.W.

      Judiciary
      Plaza

      Washington,
      D.C. 20549-0405

      Attention:
       Mellissa
      C. Duru

      James
      Murphy

      Tangela
      Richter

      H.
      Roger Schwall

Re: McMoRan
Exploration Co.

Form S-3
filed April 19, 2005

File No.
333-121779

Form 10-K
for the fiscal year ended December 31, 2004, filed March 15, 2005

Response
Letter dated May 5, 2005

Ladies
and Gentlemen:

On behalf
of McMoRan Exploration Co. (“McMoRan”), we are submitting this letter in
response to the comment received from the Commission’s staff (the “Staff”) by
facsimile on May 11, 2005, with respect to our previous response letter to you
dated May 5, 2005, regarding our Form 10-K for the fiscal year ended December
31, 2004. We have reproduced below the full text of the Staff’s comment in
italics, which is followed by our response. We also note that our response
reflects the points that we discussed with Mr. James Murphy of the Staff in a
telephone conference on May 13, 2005.

Form
10-K as of December 31, 2004, filed on March 15, 2005

Supplementary
Oil and Gas Information

Standardized
Measure of Discounted Future Net Cash Flows

Comment
1: In
regards to your response number 1 of your letter dated May 5, 2005, please
indicate specifically what portion of your oil and gas producing activities
suffered the tax losses. Specifically name the properties and the reason these
properties incurred the tax losses. We note that several years ago you were
engaged in activities for the recovery and processing of sulfur. Please name the
properties that these operations were conducted on and confirm that the tax loss
carryovers are unrelated to these operations.

Response
1: Our
Company’s business activities previously included both oil and gas and sulphur
operations. We ceased our sulphur mining operations in August 2000 and sold all
our remaining sulphur transportation and marketing business operations in June
2002.

Our oil
and gas operations have consisted of exploration, development and production
activities, primarily offshore in the Gulf of Mexico. Our former sulphur
operations consisted of the transportation, terminaling, processing and
marketing of sulphur produced from our offshore sulphur mines and sulphur
purchased from third-party recovered sulphur producers involved in crude oil
refining and oil and gas processing. As described further below, our oil and gas
operations and our former sulphur operations have always been separate,
distinguishable business segments.

    ·

      Our
      oil and gas operations do not produce sulphur other than incidental
      volumes associated with oil and gas production and our former sulphur
      operations did not include the exploration, development or production of
      oil and gas. Oil produced at Main Pass Block 299, the location of our
      former sulphur mine, was included in our oil and gas operations for
      segment reporting purposes.

    ·

      In
      addition to accounting for our oil and gas operations and our former
      sulphur operations as separate, distinguishable business segments, we have
      also for income tax purposes separately distinguished between the net
      operating loss and other tax credit carryforwards attributable to our oil
      and gas operations and to our former sulphur operations. At December 31,
      2004, our tax loss carryforwards and future tax deductions in excess of
      book basis were as follows (in millions):

      Oil
      and Gas

      $

      327.6

      Sulphur

      258.6

      Total

    $

      586.2

    ·

      The
      above amounts from our oil and gas operations primarily reflect drilling
      and related leasehold costs associated with nonproductive exploratory
      wells, as well as a portion of our drilling costs related to our
      productive wells (intangible well drilling costs, which are amortized over
      a time-frame in accordance with tax regulations), relating to oil and gas
      operations on various properties since our McMoRan’s inception.

    ·

      Our
      sulphur mining operations were conducted at various times at (1) Main Pass
      Block 299 located in federal waters of the Gulf of Mexico; (2) Caminada,
      Grand Ecaille, Grand Isle and other mines located on-shore or off-shore
      Louisiana; and (3) the Culberson mine located in west Texas.

_________________________

McMoRan
represents to the Commission and its Staff that McMoRan is responsible for the
adequacy and accuracy of the disclosure in its filings. McMoRan further
acknowledges that 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. In addition, McMoRan will 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
for your assistance with these matters. If you have any questions or comments,
please call me at your earliest convenience at (504) 582-1812.

Sincerely,

/s/ Nancy
D. Parmelee

Nancy D.
Parmelee

Senior
Vice President, Chief Financial

Officer
& Secretary

cc:
 Douglas
N. Currault II

Kathleen
L. Quirk

C. Donald
Whitmire, Jr.