SecProbe.io

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Mail Stop 3561

				September 29, 2005

By Facsimile and U.S. Mail

Mark Leland
Chief Financial Officer
El Paso Corporation
1001 Louisiana Street
Houston, TX 77002

		Re:	Southern Natural Gas Company
			Form 10-K for the year ended December 31, 2004
			Filed March 29, 2005
			File No. 1-2745

Dear Mr. Leland:

      We have reviewed your filings and have the following
comments.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
Please be as detailed as necessary in your explanation.   After
reviewing this information, we may or may not raise additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Southern Natural Gas Company Form 10-K for the year ended December
31, 2004

General

1. Your approved FERC rate of return is useful information.
Prospectively, please disclose such information.

2. Explain to us what consideration you gave to the adoption of
SFAS
no. 143.  Please be detailed in your response.

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 5

Capital Expenditures, page 8

3. Explain to us your capitalization policy with respect to
maintenance expenditures.  In this regard, we noted a significant
increase in the amount of capitalized maintenance expenditures in
2004, as compared with 2003.  Also, explain if your capitalization
policy is consistent with that of your parent.

1. Basis of Presentation and Summary of Significant Accounting
Policies, page 21

4. Prospectively, ensure that you will disclose the composite
rates
of depreciation for your regulated property.

2. Income Taxes, page 25

5. Explain if you have provided a deferred tax liability for the
equity component of the allowance for funds used during
construction.

Debt and Other Credit Facilities, page 27

6. Prospectively, enhance your long-term debt table to include the
month that your bonds will mature.  Please also disclose any call
or
sinking fund terms or indicate which bonds are non-callable.  See
Rule 5-02 of Regulation S-X as well as paragraph 4 to SFAS no.
129.

11. Investments in Unconsolidated Affiliates and Transactions with
Affiliates, page 35

7. Please reconcile the amount of income recorded from your equity
method investments to the amount reported on the investee`s
consolidated statements of income.  Furthermore, explain in detail
why you have timing differences related to these investees, and
quantify such differences for the past three years.
``````````````````````````````
		Please respond to these comments within 10 business days
or
tell us when you will provide us with a response.  Please furnish
a
letter with your responses to our comments and provide any
requested
supplemental information.  Please understand that we may have
additional comments after reviewing your responses to our
comments.
Please file your response letter on EDGAR as a correspondence
file.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

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

* 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; 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.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

		If you have any questions regarding this comment, please
direct them to Robert Babula, Staff Accountant, at (202) 551-3339
or,
in his absence, to the undersigned at (202) 551-3841.  Any other
questions regarding disclosures issues may be directed to H.
Christopher Owings, Assistant Director at (202) 551-3725.

		Sincerely,

		Michael Moran, Esq.
		Branch Chief

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Mr. Mark Leland
Southern Natural Gas Company
September 29, 2005
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