SecProbe.io

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                   [Letterhead of THE MONARCH CEMENT COMPANY]

                                                           April 6, 2005

Mr. Rufus Decker
Accounting Branch Chief
Securities and Exchange Commission
Washington, D.C. 20549-0510

     Re:  Form 10-K for the fiscal year ended December 31, 2004
          File No. 0-2757

Dear Mr. Decker:
     I am in receipt of your letter dated March 18, 2005 regarding the
staff's review of The Monarch Cement Company's Form 10-K for the fiscal year
ended December 31, 2004.  As per your request, please find below our
responses to the comments you provided.  On the whole, we believe that your
comments are appropriate and that their implementation will improve the
information we provide to investors.  In considering your comments, we
believe that, while there are improvements that we can make in our filing,
amending the existing filing on Form 10-K for the fiscal year ended December
31, 2004 will not be necessary.  Additionally, the company anticipates that
these items will be incorporated into the Company's Form 10-Q for the quarter
ended March 31, 2005, where applicable.
FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004:
Comment Applicable to Your Overall Filing
1.	Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response what
the revisions will look like.  These revisions should be included in
your future filings.
Response:
We have included below responses to each of the specific comments you
have provided and will implement these in future filings.
Item 5. Market for Registrant's Common Equity and Related Stockholder Matters
2.	Please expand your disclosure to include information relating to your
dividend policy and your ability to pay such dividends, including any
restrictions on paying dividends imposed on you by your debtors.  Refer
to item 201(c) of Regulation S-K.
Response:
The Company will include the following disclosure in its future
periodic filings to comply with the requirement to disclose dividend
policy:
The Company's Board of Directors is responsible for determining
the amount and timing of dividend payments.  In recent years, the
Company has paid four dividends per year of $.20 per share.  All
dividends are discretionary and are based on past financial
performance and availability of funds.  The Company is not
restricted regarding payment of dividends, but does have a
financial covenant related to net worth.

Item 9A. Controls and Procedures
3.	Your disclosure controls and procedures should have been evaluated as
of the end of the period as opposed to within 90 days of the filing
being made.  Please revise your disclosure accordingly.
Response:
The Company will include the following disclosure in its future
periodic filings to comply with the requirement that such disclosure
controls and procedures will have been evaluated as of the end of the
period:
As of the end of the period covered by this report, an evaluation
was carried out by the Company's management, including its
President and Chairman of the Board of Directors and Chief
Financial Officer, of the effectiveness of its disclosure
controls and procedures (as defined in Rule 13a-15(e) under the
Securities Exchange Act of 1934). Based upon that evaluation, the
Company's President and Chairman of the Board of Directors and
Chief Financial Officer concluded that these disclosure controls
and procedures were effective as of the end of the period covered
by this report.

EXHIBIT 13
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Results of Operations
4.	Your discussion regarding your results of operations cites many
different factors that are attributable to the changes in your income
statement line items.  Please expand your disclosure to quantify the
affects each of these components had on the changes within the income
statement, including information on offsetting components.  Some
examples include, but are not limited to the following:
*	Gross profit
*	fuel costs and
*	pension costs
*	Selling, general and administrative
*	pension costs and
*	corporate insurance costs
*	The reason for the changes in effective tax rates
Response:
The Company will expand our discussion of changes in income statement
line items in its future periodic filings to include more detailed
explanations such as the following:
       2004 Compared to 2003
Our overall gross profit rate for the year 2004 was 9.7% compared
to 13.7% for the year 2003.  Gross profit rate in the Cement
Business increased less than .5%.  In late 2004, we began to
benefit from our new coal firing system reducing our dependence
on natural gas and reducing our fuel costs by approximately $1.7
million.  We also benefited from a reduction in pension expense
of approximately $.2 million due to higher stock market prices at
the end of 2003; however, these reductions were offset by
slightly higher labor and health insurance costs of approximately
$.6 million and $.9 million, respectively.  Gross profit rate in
the Ready-Mixed Concrete Business decreased 5.4%.  This decrease
in gross profit rate was primarily due to the costs associated
with the construction contracts as discussed under "General"
above.  Gross profit from construction contracts decreased
approximately $3.1 million creating a loss on these contracts.
Increases in raw material costs and fuel of approximately $.6
million and $.3 million, respectively, also contributed to the
decrease in gross profit for this line of business.

"Other, net" increased approximately $1.3 million for the year
2004 as compared to the year 2003 primarily due to an increase in
the amount of gain realized on the sale of other equity
investments of approximately $.7 million and an increase in
subsidiary losses allocated to minority interest of approximately
$.5 million.

The effective tax rates for years 2004 and 2003 were 34.4% and
28.9%, respectively.  The Company's effective tax rate differs
from the federal and state statutory income tax rate primarily
due to the effects of percentage depletion, minority interest in
consolidated income (loss) and valuation allowance.  During 2004,
a valuation allowance increased the effective tax rate by 16.9%.
This increase was substantially offset by the effects of
percentage depletion and minority interest in consolidated income
(loss) which reduced the effective tax rate by 13.3% and 3.5%,
respectively.  During 2003, percentage depletion reduced the
effective tax rate by 7.2%.

       2003 Compared to 2002
Our overall gross profit rate for the year 2003 was 13.7%
compared to 15.6% for the year 2002.  Gross profit rate in the
Cement Business decreased less than .5%.  Higher fuel costs of
approximately $3.8 million due to burning natural gas in our
precalciner kiln and higher pension costs of approximately $.6
million due to lower stock market prices at the end of 2002 were
offset by slightly lower labor costs of approximately $.3 million
as a result of reduced overtime, an increase in the gain on the
sale of fixed assets of approximately $.9 million and an increase
in cement and work in process added to inventory with a resulting
decrease in cost of sales of approximately $3.4 million.  Gross
profit rate in the Ready-Mixed Concrete Business decreased 2.8%.
This decrease in gross profit rate was primarily due to the
reduced utilization of manpower and equipment due to lower sales
volumes.  Increases in fringe benefits of approximately $.3
million, primarily related to health insurance, and depreciation
expense of approximately $.6 million also contributed to the
reduction in gross profit rate for this line of business.

Selling, general and administrative expenses increased 7.9%
during the year 2003 compared to the year 2002.  These costs are
normally considered fixed costs that do not vary significantly
with changes in sales volume.  The increases are primarily due
to:  increases in pension expense of approximately $.2 million as
a result of lower stock market prices at the end of 2002;
increased corporate insurance costs of approximately $.3 million
due primarily to increases in umbrella and general liability
rates and the addition of directors' and officers' insurance;
rising health care costs of approximately $.2 million; and the
addition of sales personnel in the Ready-Mixed Concrete Business
of approximately $.1 million.

"Other, net" increased approximately $1.6 million for the year
2003 as compared to the year 2002 primarily due to an increase in
the amount of gain realized on the sale of other equity
investments of approximately $.6 million, an increase in
miscellaneous sales of approximately $.4 million, an increase in
subsidiary losses allocated to minority interest of approximately
$.2 million and a 2002 write-off of obsolete equipment of
approximately $.2 million.

The effective tax rates for years 2003 and 2002 were 28.9% and
32.4%, respectively.  The Company's effective tax rate differs
from the federal and state statutory income tax rate primarily
due to the effects of percentage depletion and minority interest
in consolidated income (loss).  During 2003 and 2002, percentage
depletion reduced the effective tax rate by 7.2% and 5.3%,
respectively, accounting for the majority of the reduction in the
effective tax rate.

Liquidity
5.	You have disclosed in Item 2 of your Form 10-K for the year ended
December 31, 2004 that you have scheduled the installation of the
clinker cooler and made preliminary plans for installation on the
second precalciner you purchased.  Please expand your disclosure to
include the expected cost of the installations, the cost of the
equipment, and related depreciation taken on this equipment, if any.
Please also disclose how long these installations will each take and
how that will impact your operating results during these periods.
Response:
The Company will expand our liquidity discussion in its future periodic
filings to include more detailed explanations of large capital
expenditures such as the following:
The Company has scheduled the installation of a new clinker
cooler in early 2005.  We previously spent approximately $.4
million on cooler equipment and expect to spend an additional $4
million on mechanical construction, refractory and electrical
parts and installation.  Although we will have to shutdown our
preheater kiln for about six weeks during installation, we are
projecting a slight increase in total clinker production for the
year 2005 as compared to 2004.  During 2004, our precalciner kiln
was shutdown for approximately 3 weeks (to connect the new coal
firing system and to perform other maintenance designed to
improve performance) reducing clinker production during 2004.
The precalciner kiln, which has a larger production capacity,
will continue to operate during the cooler installation allowing
us to increase production compared to 2004.  We have not started
depreciating this equipment.

The Company has preliminary plans to convert our remaining
preheater kiln to a precalciner kiln in 2006.  We have previously
spent approximately $7.6 million on equipment and expect to spend
an additional $10.5 million on installation, electrical and
refractory to complete the conversion.  Installation could begin
in early 2006 and be completed in about two months.  The
conversion of this kiln should increase our production capacity
by approximately 200,000 tons per year.  We have not started
depreciating this equipment.

6.	Please revise your table of contractual cash obligations to include
planned funding of pension and other postretirement benefit obligations
and estimated interest payments on your debt.  Because the table is
aimed at increasing transparency of cash flow, we believe these
payments should be included in the table.  Please also disclose any
assumptions you made to derive those amounts.
Response:
The Company will expand our contractual cash obligations table in its
future periodic filings to include planned funding of pension and other
postretirement benefit obligations and estimated interest payments on
our debt as indicated in the following revised table:
Contractual obligations at December 31, 2004, consisting of
maturities of long-term debt, line of credit, estimated interest
payments on debt and other postretirement benefit obligations,
are as follows:

<Table>

<Caption>

                         2005        2006	        2007        2008	        2009      Thereafter
<S>                   <C>         <C>         <C>         <C>         <C>          <C>
Long-term debt        $2,265,689  $	2,312,642  $2,422,784  $2,535,795  $16,571,292  $  276,602
Line of credit           981,667       -           -           -            -           -
Interest payments      1,228,513   1,077,385     	967,243     854,231      730,969      12,819
Postretirement
  benefit obligations    936,590     980,124   	1,035,184   	1,067,481    1,096,591   5,922,564

</Table>

The Company has been required to make a pension contribution in
only one of the past 5 years.  In 2003, the Company contributed
approximately $320,000 to the pension fund.  During 2005, the
Company does not anticipate making any material contributions
into the plan.

7.	Please expand your disclosure to discuss your expectations regarding
the declaration and payments of future dividends.
Response:
The Company will expand our disclosure in future periodic filings to
discuss our expectations regarding the declaration and payments of
future dividends as follows
For several years the Company has paid a $.20 per share dividend
in January, March, June and September.  Although dividends are
declared at the Board's discretion, we project future earnings
will support the continued payment of dividends at the current
level.

Financial Statements
Statements of Cash Flows
8.	Please present the cash inflows and outflows related to the following
on a gross basis:
*	net purchases of subsidiaries' stock and
*	proceeds from (retirement of) bank loans.
Otherwise, please explain to us how they meet the criteria in SFAS 95 for
netting.  Only cash flows stemming from investments, loans and debt with
original maturities of three months or less may be reported on a net basis.
Response:
The Company did not sell any subsidiary stock during 2002, 2003 or
2004; therefore, net purchases of subsidiaries' stock included only
purchases of subsidiaries stock.  The Company will present cash inflows
and outflows on a gross basis in its future periodic filings as
follows:

<Table>

<Caption>

                                      2004          2003          2002
<S>                               <C>           <C>           <C>
Purchases of subsidiaries' stock  $  (118,999)  $  (128,508)  $(2,421,057)
Increase (decrease) in line of
 credit, net                          981,667    (3,048,076)   (1,951,924)
Proceeds from bank loans            5,805,645         -         5,100,345
Payments on bank loans             (2,527,258)   (3,278,387)        -
Payments on other long-term debt     (186,048)     (213,473)        -

</Table>

9.	Please disclose in a footnote the income statement line item that you
include the (gain) loss on disposal of assets in.  If you exclude these
amounts from income from operations, please tell us how you considered
the guidance in paragraph 45 of SFAS 144 in doing so.
Response:
The Company will present the following additional information in its
future periodic filings:
The Company includes the (gain) loss on disposal of assets in
cost of sales.

Notes to Financial Statements
(1) Nature of Operations and Summary of Significant Accounting Policies
10.	Please disclose the types of expenses that you include in the cost of
sales line item and the types of expenses that you include in the
selling, general and administrative expenses line item.  Please also
disclose whether you include inbound freight charg