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Response to SEC Comment Letter dated 8/24/2005

EnergyEast

Robert D. Kump

Vice President, Controller and Chief Accounting Officer

Energy East Corporation

52 Farm View Drive

New Gloucester, ME 04260

Phone: (207) 688-4302 / Fax (207) 688-4331

E-Mail:robert.kump@energyeast.com

September 8, 2005

By EDGAR and Facsimile

Mr. James Allegretto

Senior Assistant Chief Accountant

Division of Corporation Finance

United States Securities and Exchange Commission

Mail Stop 3561

100 F Street, NE

Washington, D.C. 20549

RE:     Energy East Corporation, File No. 1-14766

           Central Maine Power Company, File No. 1-5139

           New York State Electric & Gas Corporation, File No. 1-3103-2

           Rochester Gas and Electric Corporation, File No. 1-672

           Form 10-K for the year ended December 31, 2004

           Filed March 14, 2005

Dear Mr. Allegretto:

          This letter is in response to the Division of Corporation Finance's comment letter dated August 24, 2005, in which you requested additional information based on your review of our filings on Form 10-K for the year ended December 31, 2004, and Form 10-Q for the quarter ended June 30, 2005. In this letter we will refer to the companies as follows: Energy East Corporation and its subsidiaries - Energy East or the company, Central Maine Power Company - CMP, New York State Electric & Gas Corporation - NYSEG, and Rochester Gas and Electric Corporation - RG&E. In addition, we refer to Connecticut Natural Gas Corporation as CNG and The Southern Connecticut Gas Company as SCG. The comments included in your letter are repeated below, and our response immediately follows each comment.

          In connection with the filing of our responses to your comments, the company acknowledges that:

the company is responsible for the adequacy and accuracy of the disclosure in the filings;

staff comments or changes to disclosures in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and

the company 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.

September 8, 2005

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          If you have questions concerning any of our responses, please feel free to contact me at 207-688-4302 or Curtis Call at 207-688-4355.

Sincerely,

/s/Robert D. Kump

Robert D. Kump

Vice President, Controller & Chief Accounting Officer

September 8, 2005

Page 3

Energy East Corporation Form 10-K for the Year Ended December 31, 2004

General

While the majority of the proceeding comments were issued under the heading of Energy East Corporation, our review encompassed all 4 registrants enumerated on the facing page of your Form 10-K. Accordingly, most of the comments, while written with Energy East's specific information, have equal applicability to the related subsidiary(s) narrative or financial statements. Please confirm that in responding to the aforementioned comments you will also respond to the comment to the extent it has any direct or indirect applicability to the related subsidiary(s) registrant.

Response: In responding to the aforementioned comments we confirm that we will also respond to each comment to the extent that it has any direct or indirect applicability to our subsidiary registrants.

With respect to future filings by our subsidiary registrants, please note that on March 24, 2005, NYSEG filed a Form 15 with the Commission and on June 20, 2005, CMP filed a Form 15 with the Commission, each terminating its respective status as a registrant under the Securities Exchange Act of 1934 (Exchange Act).

In our Exchange Act filings, amounts presented in our companies' financial statements and notes to financial statements are expressed in thousands, although amounts in results of operations discussions are generally expressed in millions. Therefore, we assume that in your comment letter references to amounts in millions was intended to be in thousands.

Management's Discussion and Analysis of Financial Condition and Results of Operations

Natural Gas Delivery Business

Explain to us if you have any fixed payments associated with your natural gas agreements, such as amounts related to obtaining firm transportation, and if so, then please explain if such amounts have been included in your contractual obligations table. In this regard, you may want to footnote the nature of "unconditional purchase obligations" in your contractual obligations and commercial commitments disclosure.

Response: Energy East has fixed payments associated with natural gas capacity contracts that are included in the amounts in the contractual obligations table under the heading "Unconditional purchase obligations." The amounts associated with the natural gas capacity contracts are (in thousands): Total - $386,823; 2005 - $103,275; 2006 - $93,248; 2007 - $85,372; 2008 - $77,297; 2009 - $17,753; and After 2009 - $9,878. In our future Exchange Act periodic reports, Energy East will separately present or footnote the nature of unconditional purchase obligations included in the contractual obligations and

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commercial commitments disclosure, as appropriate. NYSEG and RG&E separately disclosed the amounts associated with natural gas capacity contracts in their 2004 Form 10-K contractual obligations tables, and RG&E will continue to do so.

Management's Discussion and Analysis of Financial Condition and Results of Operations

Operating Expenses

Prospectively, ensure that your narrative regarding changes in revenues and expenses are numerically consistent with the changes reported. For example, you disclose that operating expenses decreased by $84 million in 2004, although your analysis nets to a change of $60 million. While we note you use the word "primarily" in describing the components of the fluctuation, please advise whether such analysis could be enhanced by the addition of the remaining items.

Response: In our future Exchange Act periodic reports for Energy East and RG&E, we will enhance our narratives regarding changes in revenues and expenses by ensuring that they are more detailed and represent a greater portion of the changes reported, including an enhanced explanation in our 2005 Form 10-K of the $84 million decrease in operating expenses for 2004.

Consolidated Balance Sheets

Explain to us what comprises other regulatory assets and liabilities totaling $419,214 million and $107,932 million, respectively. If the detail of the most recent balance sheet is qualitatively or quantitatively different that the preceding year, provide us the detail of the preceding year. Furthermore, please provide a brief description and probability recovery assessment of each regulatory asset you list. You may want to consider enhancing your regulatory asset and liability disclosure in your significant accounting policy note to provide more detail about amounts and descriptions of your other regulatory assets and liabilities. We believe that disclosing the recovery/refund period along with information as to whether previously expended amounts are earning a return is useful information to a reader.

Response: Attachment A provides detail of the items and corresponding amounts that comprise total "Other regulatory assets" and "Other regulatory liabilities" for Energy East, CMP, NYSEG and RG&E at December 31, 2004. The detail for December 31, 2004, is qualitatively the same as the detail for the previous year. A brief description and probability assessment for each regulatory asset listed is also provided in Attachment A.

In our future Exchange Act periodic reports, Energy East and RG&E will enhance the disclosure in their significant accounting policies note to the financial statements to provide more detail about amounts and descriptions of other regulatory assets and liabilities, to the extent they are material. Such enhancement would include disclosing the

September 8, 2005

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recovery/refund period when such a period has been specified, in addition to the information currently provided in the significant accounting policies note about whether previously expended amounts are earning a return.

Explain to us what comprises other property and investments, net totaling $190,148 million as of December 31, 2004.

Response: Energy East's "Other property and investments, net" of $190,148 thousand at December 31, 2004, represents approximately 2% of total assets at that date. Attachment B provides detail of the items and corresponding amounts that comprise "Other property and investments, net" for Energy East, CMP, NYSEG and RG&E at December 31, 2004. In our future Exchange Act periodic reports, to the extent that the amounts are material, we will provide detail of the items that comprise Energy East's and RG&E's "Other property and investments, net."

Note 1. Significant Accounting Policies

Basic and diluted earnings per share

Please tell us the difference between shares excluded from EPS and potentially dilutive common shares. Tell us whether the shares excluded from EPS represent shares underlying options and how the number of shares was calculated.

Response: Potentially dilutive shares are those that may be acquired under a stock option, which is issued in tandem with a stock appreciation right (SAR), and for which the exercise price is less than the market price of the stock during the period, such that the exercise of the stock option/SAR would result in dilution under the treasury stock method in accordance with SFAS 128, Earnings per Share. When the exercise price of a stock option/SAR is greater than the market price of Energy East's common stock an exercise would be antidilutive, and the shares are excluded from the EPS calculation for the period. The number of shares excluded is calculated as the total underlying shares for which the exercise price of the stock option/SAR exceeded the average market price for the applicable period.

Depreciation and Amortization

Prospectively, present your balances of major classes of unregulated depreciable property by nature or function. See paragraph 5 of APB 12.

Response: Energy East's unregulated depreciable property totaled $73 million at December 31, 2004, which was less than 1% of gross plant. RG&E has no unregulated depreciable property. In our future Exchange Act periodic reports, to the extent that the amounts become material, we will present Energy East's major classes of unregulated depreciable property by nature or function, in accordance with paragraph 5 of APB 12.

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Please explain what type of generation assets require estimated cost of removal to be included in the determination of depreciation expense. Absent rate recovery for non-SFAS 143 negative salvage costs, we are not clear on the basis for recognition in the income statement. If you are recovering a portion of your non-legal in rates, we believe that a portion of your depreciation expense being recovered represents a regulatory liability. Please explain to us in detail how you are accounting for legal and non-legal closure costs on generation assets and how such amounts are reflected in the balance sheet.

Response: Effective with the sale of the Ginna nuclear generation station (Ginna), Energy East and RG&E no longer have any generation assets with associated asset retirement obligations (legal closure costs). Energy East and RG&E have generating assets for which cost of removal is included in depreciation expense (nonlegal closure costs). The amount included in depreciation expense is consistent with amounts allowed in rates for cost of removal. In accordance with paragraph B73 of SFAS 143, Accounting for Asset Retirement Obligations, the accumulated balance of revenues collected in excess of actual removal costs incurred is reclassified from accumulated depreciation to a regulatory liability, accrued removal costs.

The depreciation rates for NYSEG's generation assets do not include a cost of removal component and consequently no nonlegal closure costs are recognized for its generating assets. CMP no longer owns any generation assets.

Revenue Recognition

Explain to us how you determine what power sales and purchases to the NYISO to net. In this regard, we note a diversity in practice when a central market, such as an ISO exists and the load serving entity buys and sells into the ISO at various times in the day, week or month. Please provide your accounting rationale for the net treatment and contrast your treatment with other utilities that buy and sell into the NYISO.

Response: Both NYSEG and RG&E have purchase and sales transactions with the NYISO. Generation (megawatt-hours) from the companies' owned sources is sold to the NYISO and, to the extent that the generated megawatt-hours are needed to meet NYSEG's and RG&E's system load requirements, they are repurchased from the NYISO at approximately the same price. Those transactions are netted and do not result in either purchased power expense or wholesale sales revenue. The accounting rationale for the net treatment is to eliminate the grossing up of purchases and sales and to present the transactions after the formation of the NYISO in a manner comparable to the way the companies used their generation prior to the formation of the NYISO. There was no wholesale sales revenue and no purchased power expense in connection with the power generated from NYSEG's and RG&E's owned sources when that generation was used to meet system load requirements.

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Purchases pursuant to various contracts, including power purchased from Nine Mile Point 2 nuclear generating station and Ginna and for the output from various nonutility generators are also transacted through the NYISO. In such circumstances the company pays the generator the contract price for the power and the costs are recorded as purchased power expense.

If either NYSEG or RG&E needs additional power, or has excess power, it would purchase power from or sell power to the NYISO on either the day ahead or spot market as appropriate. No netting would occur for these transactions, which are recorded either as purchased power expense or wholesale sales revenue.

Energy East has three unregulated subsidiaries that conduct transactions with the NYISO. Energetix, Inc. and NYSEG Solutions, Inc. buy power from the NYISO to supply their electricity customers, and Cayuga Energy, Inc. sells the output from its generating plants into the NYISO. There is no netting in connection with these transactions.

Other than the limited information provided in publicly available Commission filings, the company is not aware of the accounting treatment followed by other utilities that buy and sell into the NYISO.

Other (Income) and Other Deductions

Explain to us what comprises miscellaneous income and expenses totaling $20,033 million and $15,023 million, respectively for the year ended December 31, 2004.

Response: Attachment C provides descriptions and the corresponding amounts that comprise the totals of "Miscellaneous other (income)" and "Miscellaneous other deductions" for Energy East, CMP, NYSEG and RG&E for the year ended December 31, 2004.

Beginning with the filing of our Form 10-Q for the quarter ended March 31, 2005, we are providing more detail concerning "Other (Income) and Other Deductions" in the notes to the financial statements (Note 2 for the quarter ended March 31, 2005), and intend to provide a similar level of detail in future Exchange Act periodic reports.

Note 2. Sale of Ginna

Explain to us management's intention with respect to Ginna prior to the sale. In this regard, help us understand when management decided to initially sell Ginna. Also, explain what consideration you gave to classification of Ginna as discontinued operations with the related net assets as held for sale.

September