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                  NATIONAL HOUSING PARTNERSHIP REALTY FUND I
                         55 Beattie Place, P.O. Box 1089
                              Greenville, SC 29602

May 10, 2005

Correspondence Filing Via Edgar and Overnight Delivery

United States Securities and Exchange Commission
Division of Corporation Finance
Mail Stop 0409
450 Fifth Street, NW
Washington, D.C.  20549
Attn:  Mr. Steven Jacobs

Re:   National Housing Partnership Realty Fund I
      Form 10-KSB for the year ended December 31, 2004 File No. 0-13465

Ladies and Gentlemen:

This letter responds to the comments of the staff of the Securities and Exchange
Commission (the "Staff")  addressed to National Housing  Partnership Realty Fund
I, a Maryland limited partnership (the  "Partnership"),  in a letter dated April
13, 2005.  The  Partnership  appreciates  the Staff's  willingness to provide an
extension of time for this response.  The Partnership's  response to the Staff's
comments are set forth below and are numbered to  correspond to the numbering of
the Staff's comments in the Staff's letter.

                        *     *     *     *     *

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

Note 1 - Organization and Summary of Significant Accounting Policies

Significant Accounting Policies

      1. Comment: In a supplemental response,  please tell us how you determined
      to account for your  investments  using the equity  method for each of the
      three partnerships in which you own a 98% or more interest.  Specifically,
      address the criteria for important rights in paragraph 9 and the substance
      of the  partnership  arrangement in paragraph 10 of SOP 78-9.  Please cite
      relevant terms of the partnership agreements, as appropriate.

     Response: The Partnership made its initial determination to account for its
     investments in the local limited  partnerships  at the time the Partnership
     became  the  limited  partner   investor  in  each  of  the  local  limited
     partnerships.  This  evaluation  included a review of the  related  limited
     partnership  agreements  of  each  of the  local  limited  partnerships  to
     understand the rights and  obligations of the respective  general  partners
     and the  Partnership,  as  limited  partner.  It should  be noted  that the
     general  partner  of the  Partnership,  The  National  Housing  Partnership
     ("NHP"),  also serves as the general  partner of each of the local  limited
     partnerships.  Each  of the  limited  partnership  agreements  provide  the
     respective general partners with the following rights and obligations:

o     The local limited  partnership  shall be managed and its business  shall
           be controlled by the general partner
o     Limited  partners  shall not take part in the  management  or control of
           the local limited partnership's business
o     The general  partner has the ability to designate the  management  agent
           for the local limited partnership
o     The general  partner is authorized to sell all or  substantially  all of
           the assets of the local limited partnership
o     The  limited  partner  does  not have the  right  to force  the  general
           partner to sell assets
o     The limited  partner does not have the right to structure the terms of a
           proposed sale of assets

        Although each general  partner  historically  has  controlled  the major
        operational and financial policies of the local limited  partnership for
        which it serves as  general  partner by  exercising  the above and other
        rights  stated in the  respective  limited  partnership  agreement,  the
        Partnership,  as limited  partner,  has  certain  "important  rights" as
        contemplated in paragraph SOP 78-9, as follows:

o    The limited partner has consent rights to the sale of all or  substantially
     all of the assets of the local limited  partnership  o The limited  partner
     has the right to  remove  the  general  partner  without  cause and elect a
     successor  general  partner upon a vote of the limited  partners  holding a
     majority (more than 50%) of the  percentage  interests in the local limited
     partnership.

     The  Partnership  believes that these  "important  rights" provide that the
     local  limited  partnerships  are  not  under  the  control,   directly  or
     indirectly,  of NHP and therefore  preclude NHP, as general  partner,  from
     consolidating  its  investments  in the local  limited  partnerships  under
     paragraph 9 of SOP 78-9. The Partnership  further  considered  whether such
     limited partner rights, in conjunction with the Partnership's  ownership of
     more than a majority of the limited partner  interests,  could  effectively
     result in the  Partnership  having control over the major  operational  and
     financial policies of the local limited partnerships, which would result in
     the Partnership  consolidating the local limited partnerships in accordance
     with paragraph 10 of SOP 78-9.

        Notwithstanding the "important rights" of the limited partner[s] and the
        Partnership's majority ownership,  the Partnership has concluded that it
        does not control the local  limited  partnerships,  based on two primary
        factors:  (1) the provisions of each limited  partnership  agreement for
        each local limited partnership that specifically  provides operating and
        financial  control  to each  general  partner  and (2) the  demonstrated
        exercise of that  control by each general  partner over the  twenty-year
        history of the local limited partnerships.

        Based on the foregoing considerations,  the Partnership does not control
        major operating and financial policies of the local limited partnerships
        and therefore uses the equity method of accounting  for its  investments
        in each of the local limited  partnerships  in accordance with paragraph
        10 of SOP 78-9.

Recent Accounting Pronouncements

        2. Comment:  In a  supplemental  response,  please tell us the basis for
        your determination the partnerships are not VIEs. Specifically,  address
        the proportional voting rights and entity activities conducted on behalf
        of any investor  that may have  disproportionately  few voting rights as
        described in paragraph  5c of FIN 46. In doing so,  please  explain your
        relationship with the general partner of each Local Limited  Partnership
        and how you considered that relationship in your analysis. Additionally,
        address the decision making rights and related equity investment at risk
        of the holders of the equity investment as described in paragraph 5b.

        Response:  The  Partnership's   determination  that  the  local  limited
        partnerships  are not VIEs was made based on consideration of paragraphs
        5, 9 and 10 of FASB  Interpretation  No.  46  (revised  December  2003),
        Consolidation of Variable  Interest  Entities (FIN 46R). The Partnership
        first  considered  paragraph  5(b)(1) of FIN 46R and determined that the
        group of  equity  holders  at risk  was  comprised  only of its  limited
        partners  (the group that  contributed  the  capital  necessary  to fund
        acquisition properties owned by local limited partnerships). The general
        partners were not considered to have  significant  equity at risk either
        because their capital  contributions were insignificant or because their
        initial capital contributions were offset by fees received at inception.
        The limited  partners  were  deemed to have the right to make  decisions
        that have a  significant  effect  on the  success  of the local  limited
        partnership  through their ability to remove the general partner without
        cause.

        The Partnership next considered  paragraph  5(b)(2) and determined based
        on  review of local  limited  partnership  agreements  that the group of
        equity holders at risk (the limited partners) do not lack the ability to
        absorb expected  losses,  are not protected from the expected losses and
        are not guaranteed a return.

        The Partnership next considered  paragraph  5(b)(3) and determined based
        on  review of local  limited  partnership  agreements  that the group of
        equity  holders at risk (the  limited  partners) do receive the expected
        residual returns and are not subject to caps on expected returns.

        The Partnership  next considered  paragraph 5(c) and determined based on
        review of the local  limited  partnership  agreements  that the  general
        partner  is  generally   the  equity  holder  who  is  involved  in  the
        partnership  activity of real estate development and operations and also
        benefits through the receipt of fees for services  provided to the local
        limited  partnerships  and the right to receive  distributions  from the
        local limited  partnerships.  Therefore the Partnership does not believe
        that substantially all of the activities of the respective local limited
        partnerships  involve, and are performed on behalf of, the investor (the
        limited partner) that has disproportionately few voting rights. Also, as
        stated above, the limited partners were deemed to have the right to make
        decisions  that have a  significant  effect on the  success of the local
        limited partnerships through their ability to remove the general partner
        without cause.

        In conjunction  with the evaluation of paragraph  5(c), the  Partnership
        reviewed the  relationship  of the general partner of each local limited
        partnership  with the  Partnership.  As  previously  noted,  the general
        partner of the  Partnership,  NHP, also serves as the general partner of
        each  of the  respective  local  limited  partnerships.  The  respective
        limited   partnership   agreements  provide  that  NHP,  in  acting  and
        performing   its  duties  as  general   partner  of  the  local  limited
        partnerships,  shall at all times  exercise  its  responsibilities  in a
        fiduciary  capacity,  and in a manner  consistent with the objectives of
        NHP as set forth in Title IX of the Housing and Urban Development Act of
        1968. NHP in acting and performing its duties as general  partner of the
        Partnership  must also  exercise  its  duties in a  fiduciary  capacity.
        Therefore,  the  Partnership  determined  that  NHP  acts  in  the  best
        interests of the  respective  entities it is obligated to represent  and
        the  relationship  of  NHP  to  the  Partnership  does  not  affect  the
        Partnership's  determination that the activities of the respective local
        limited  partnerships  do not involve and are not performed on behalf of
        the  investor  (the limited  partner)  that has  disproportionately  few
        voting rights.

        Finally, the Partnership considered paragraphs 5(a), 9 and 10 of FIN 46R
        and determined  through review of financial  information  and accounting
        records for the local limited  partnerships  that the  respective  local
        limited  partnerships  lacked instances of additional  financial support
        from partners to fund  operations  (i.e. the local limited  partnerships
        have  demonstrated  that  they  can  finance  their  activities  without
        additional subordinated financial support).

        The  Partnership  believes that based upon the application of paragraphs
        5,  9  and  10  of  FIN  46R  as  discussed  above,  the  local  limited
        partnerships are not variable interest entities.

                                    * * * * *

As  requested  by  the  Staff,  the  Partnership   acknowledges  that:  (a)  the
Partnership  is  responsible  for the adequacy and accuracy of the disclosure in
the filings;  (b) Staff  comments or changes to  disclosure in response to Staff
comments do not foreclose the Commission  from taking any action with respect to
the filings;  and (c) the Partnership 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.

If you have further questions regarding the information provided, please contact
the undersigned or Stephen Waters.  Mr. Waters can be reached  directly at (864)
239-1554 or by fax at (864) 239-5824.

                                   Sincerely,

                                    /s/ David R. Robertson
                                    David R. Robertson
                                    President and Chief Executive Officer
                                    The National Housing Partnership and
                                    National Corporation for Housing
                                    Partnerships, the general partner of
                                    National Housing Partnership Realty Fund I

cc:  Stephen B. Waters

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