SecProbe.io

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Mail Stop 3561

								            August 8, 2005

Greg G. Gruber
Senior Vice President, Chief Financial Officer, Treasurer and
Director
Colorado Interstate Gas Company
El Paso Building
1001 Louisiana Street
Houston, Texas 77002

		Re:	Colorado Interstate Gas Company
			Registration Statement on Form S-4
			Filed on June 10, 2005
			File No. 333-125728
			Form 10-K for Fiscal Year Ended December 31, 2004
			Filed on March 29, 2005
			Forms 10-Q for Fiscal Quarters Ended March 31 and
June
30, 2005
			File No. 1-4874

Dear Mr. Gruber:

	We have reviewed your responses in your letter dated July 26,
2005 and have the following additional comments.  Please be as
detailed as necessary in your explanation so we may better
understand
your disclosure.  After reviewing this information, we may raise
additional comments.

	We welcome any questions you may have about our comments or
on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.

Form S-4

Environmental Matters, page 27

1. We have read your response to prior comment 3.  You indicate
that
you did not discuss the change in the environmental reserve
because
your MD&A has focused on providing forward looking information
about
known trends and future events that could have a material impact
on
your results of operations.  However, the Instructions to
paragraph
(b) of Item 303 of Regulation S-K,  in addition to encouraging
forward-looking information in MD&A, require registrants to
identify
any significant elements of the income or loss from continuing
operations which do not arise from or are not necessarily
representative of the registrant`s ongoing business.  Please
ensure
that your future MD&A disclosures are responsive to all disclosure
requirements of Item 303(b) of Regulation S-K.  In this regard, we
do
not object to your incremental disclosure of the change in
environmental reserves in the Form 10-Q for the quarter ended June
30, 2005.

2. We have read your response to prior comment 4.  Please tell us
if
your statement "we are not aware of anything that would reasonably
be
expected to result in a loss exceeding the amounts we have already
recognized" means that you do not believe it is reasonably
possible
that you will incur losses exceeding amounts already recognized.

Consolidated Statements of Income and Comprehensive Income, page
F-2

3. We have read your response to prior comment 6.  We believe that
the change from one accounting model to another is unusual as
evidenced by the FASB`s position on changes in accounting model in
paragraph 30 of SFAS 101.  Accordingly, please tell us why you do
not
believe that the FASB`s position on changes in accounting model
applies, or tell us why you believe that the reapplication of SFAS
71
would be infrequent under APB 30.

	As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your response letter as a correspondence file on
EDGAR.

	You may contact Ta Tanisha Henderson, Staff Accountant, at
(202)
551-3322, or me, at (202) 551-3843, if you have questions
regarding
comments on the financial statements and related matters.  Please
contact Matt Benson, Staff Attorney, at (202) 551-3335 with any
other
questions.
									Sincerely,

									   	George F.
Ohsiek,
Jr.
	Branch Chief
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Greg Gruber
Colorado Interstate Gas Company
August 8, 2005
Page 1

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