SecProbe.io

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            WINTHROP RESIDENTIAL ASSOCIATES I, A LIMITED PARTNERSHIP
                                7 Bulfinch Place
                            Suite 500, P.O. Box 9507
                                Boston, MA 02114

                                  July 7, 2005

VIA EDGAR
AND FACSIMILE
-------------

Securities and Exchange Commission
500 North Capital Street
Washington, D.C. 20549
Attention: Jessica Barberich

      Re:   Winthrop Residential Associates I, A Limited Partnership
            Form 10-KSB for the year ended December 31, 2004
            Filed March 31, 2005
            File No. 000-10272
            --------------------------------------------------------------------

Dear Ms. Barberich:

      On behalf of Winthrop Residential Associates I, A Limited Partnership (the
"Partnership"), we are responding to a letter dated June 22, 2005 from Daniel
Gordon to Mr. Michael L. Ashner regarding the Partnership's Form 10-KSB for the
year ended December 31, 2004.

      In this regard, please note the following:

            1. QUESTION: Please revise your filing to include the reports of the
      other auditors that you referenced in your report. The reports of
      accountants other than the principal accountant must be filed when
      reliance is placed on their work and reference is made to the reports in
      the principal auditor's report. For references see Rule 2-05 of Regulation
      S-X.

            RESPONSE: The reports of other auditors were not included in our
      filing since our investment in these partnerships is not significant. Our
      investment balance at December 31, 2004 and our revenues and expenses
      relating to these partnerships for the year ended December 31, 2004 were
      zero.

            2. QUESTION: We note that you have 93% and 95% interests in
      Stonegate Apartments Limited Partnership and College Green Limited
      Partnership, respectively, as of December 31, 2004. We also note that you
      have accounted for these investments using the equity method. Please
      advise us how you determined that you do not control either of these
      partnerships. Additionally, please tell us how you evaluated your
      interests in these limited partnerships under FIN 46(R). Specifically,
      tell us how you determined that the entities were not variable entities in
      accordance with paragraph 5 of FIN 46(R).

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            RESPONSE: Stonegate Apartments L.P. ("Stonegate") and College Green
      L.P. ("College Green") are not variable entities under paragraph 5 of FIN
      46(R) because (5.a.) the total equity investment at risk was sufficient to
      finance their activities without additional subordinated financial
      support. Stonegate's initial partner's equity contributions were
      $1,170,000 and College Green's initial partner's equity contributions were
      $787,000 (5.b.). The investors as a group do not lack any of the three
      characteristics of a controlling financial interest (i.e., voting rights,
      the obligation to absorb expected losses and the right to receive residual
      returns). The anti abuse provision (paragraph 5.c.) does not apply because
      Stonegate's and College Green's activities (rental real estate) do not
      involve and are not conducted on behalf of the Partnership, the investor
      limited partner in each of Stonegate and College Green. No significant
      events have occurred since inception which would cause a reevaluation of
      VIE status.

            For a partnership investment which is not a VIE or in which the
      Partnership is not the primary beneficiary, the Partnership follows the
      accounting set forth in AICPA Statement of Position No. 78-9 - Accounting
      for Investments in Real Estate Ventures (SOP 78-9). In accordance with
      this pronouncement, the Partnership accounts for its investments in
      partnerships and joint ventures in which it does not have a controlling
      interest using the equity method of accounting. Factors that are
      considered in determining whether or not the registrant exercises control
      include important rights of partners in significant business decisions,
      and ultimate removal of the general partner. To the extent that the
      registrant is deemed to control these entities, these entities would be
      consolidated. Determination is made on a case-by-case basis.

      We believe we have been responsive to the comments raised in your letter
and that no amendment is required to the Partnership's Form 10-KSB for the year
ended December 31, 2004. We are also providing to the Securities and Exchange
Commission an acknowledgement in the form requested. Should you have any further
questions, please call me at (617) 570-4636.

                                        Very truly yours,

                                        /s/ Thomas C. Staples

                                        Thomas C. Staples
                                        Chief Financial Officer of One Winthrop
                                        Properties, Inc., general partner

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            WINTHROP RESIDENTIAL ASSOCIATES I, A LIMITED PARTNERSHIP
                                7 Bulfinch Place
                                    Suite 500
                           Boston, Massachusetts 02114

                                  July 7, 2005

Securities and Exchange Commission
500 North Capital Street
Washington, D.C. 20549

      Re:   Winthrop Residential Associates I, A Limited Partnership
            Form 10-KSB for the year ended December 31, 2004
            Filed March 31, 2005
            File No. 000-10272
            --------------------------------------------------------------------

Gentlemen:

Reference is made to the Annual Report on Form 10-KSB for the year ended
December 31, 2004 filed by Winthrop Residential Associates I, A Limited
Partnership (the "Partnership") with the Securities and Exchange Commission (the
"Commission").

The Partnership hereby acknowledges that:

1.    The Partnership is responsible for the adequacy and accuracy of the
      disclosure made in the material that is filed with the Commission.

2.    Staff comments or changes to disclosure in response to Staff comments do
      not foreclose the Commission from taking any action with respect to the
      filed material; and

3.    The Partnership may not assert Staff comments as a defense to any
      proceeding initiated by the Commission or any person under the federal
      securities laws of the United States.

Very truly yours,

WINTHROP RESIDENTIAL ASSOCIATES I,
 A LIMITED PARTNERSHIP

By:   One Winthrop Properties, Inc.
      Managing General Partner

      By: /s/ Thomas C. Staples
          ------------------------------
          Thomas C. Staples
          Chief Financial Officer
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