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CORRESP
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corresp

October 14, 2005

Mr. William Choi

United States Securities and Exchange Commission

450 Fifth Avenue, N.W.

Washington, D.C. 20549

    Re:

    ANR Pipeline Company

Form 10-K for Fiscal Year Ended December 31, 2004

Filed March 29, 2005

File No. 1-07320

Dear Mr. Choi:

We are in receipt of your letter dated September 29, 2005, commenting on the above referenced
documents. Below are the comments contained in your letter followed by our responses. In
preparing our responses, we acknowledge the following:

    –

    We are responsible for the adequacy and accuracy of the disclosure in our filings;

    –

    Staff comments or changes to disclosure in response to staff comments do not
foreclose the Securities and Exchange Commission from taking any action with respect
to our filings; and

    –

    We 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.

Form 10-K for the Fiscal Year Ended December 31, 2004

Item 15. Exhibits and Financial Statements Schedules.

    1.

    We note that your principal auditor relied on the report of other auditors on the
financial statements of Great Lakes Gas Transmission Limited Partnership and the other
auditor stated in its report that it conducted its audits in accordance with auditing
standards generally accepted in the United States. In circumstances where a principal
auditor relies on the report of another auditor on financial statements of a non-public
entity that are filed to satisfy Rule 3-09 of Regulation S-X, the other auditor’s report
must refer to PCAOB standards. Please file a revised audit report that refers to the
standards of the PCAOB as opposed to the auditing standards generally accepted in the
United States. Please refer to Commission Release 34-49707 dated May 14, 2004 and PCAOB
Release 2003-025 (particularly Section B.2) issued December 17, 2003.

    Response

We acknowledge that the audit report provided does not comply with the Commission or the
PCAOB Releases. However, we do not believe that the audit report’s reference to GAAS, as
opposed to PCAOB standards, warrants an amendment to our Annual Report on Form 10-K for the
year ended December 31, 2004, because there would be no change in the financial information
contained in that filing, no change in the unqualified audit report rendered on those
financial statements, or in our view, no impact an investor’s ability to understand the
overall mix of information contained in the financial statements included under Rule 3-09
of Regulation S-X. Therefore, we respectfully request that we not be required to amend our
Form 10-K. As an alternative, we would propose filing the Great Lakes financial statements
with the corrected audit report on a Form 8-K.

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    2.

    We note that the audit report on the financial statements of Great Lakes Gas
Transmission Limited Partnership filed pursuant to Rule 3-09 of Regulation S-X differs
from the audit report on the financial statements of Great Lakes Gas Transmission Limited
Partnership included in a filing of one of your affiliates. Please advise.

    Response

Our Form 10-K was filed earlier than the Form 10-K of our affiliate. In the audit report
included in ANR, reference is only made to an audit conducted in accordance with US GAAS
while the later audit report of our affiliate also includes a reference to PCAOB standards.
We were aware of this difference at the time of the subsequent filing, but did not amend
our Form 10-K for the reasons stated above.

General

Should you have any further questions regarding our responses to your comments or need further
information to assist in your review, please contact me at (713) 420-4374, or Frank Olmsted,
Director of Financial Reporting, at (713) 420-3707.

    Sincerely,

    /s/ Greg G. Gruber

    Greg G. Gruber

    Chief Financial Officer

ANR Pipeline Company

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