SecProbe.io

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

June 9, 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 May 25,
2005, which was sent in response to the  Partnership's  May 10, 2005 response to
the Staff's  original  comment  letter dated April 13, 2005.  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

Financial Statements and Notes

Note 1 - Summary of  Partnership  Organization  and  Significant  Accounting
Policies

Recent Accounting Pronouncements

1.       Comment:  We do not understand how the Partnership's  ability to remove
         the general partner has significant effect on the success of the entity
         in light of your  response  to comment 1 that the  general  partner has
         operating  control and financial control through various rights and has
         "demonstrated exercise of that control...  over the twenty-year history
         of the local limited partnerships."

         Please clarify as these conclusions appear  inconsistent.  In addition,
         please tell us how various rights and  obligations  held by the general
         partner  documented  in your  response to prior comment 1 impacted your
         analysis under paragraph 5(b).

         Response:  In  developing  its response to the Staff's  comment  letter
         dated  April  13,  2005,  the   Partnership   considered   whether  its
         conclusions  under SOP 78-9 were consistent with its conclusions  under
         FIN 46R with respect to "important rights" held by the Partnership,  as
         limited  partner in the local  limited  partnerships.  These  important
         rights include the ability to remove the general partner and consent to
         the sale of substantially all assets of each local limited partnership.
         As discussed in its prior response,  the Partnership concluded based on
         specific  provisions of the  partnership  agreements and the history of
         the  local  limited   partnerships  that  the  Partnership  was  not  a
         "controlling  limited  partner" as  contemplated in paragraph 10 of SOP
         78-9.  In its  interpretation  of  paragraph  5.b(1)  of FIN  46R,  the
         Partnership concluded that the important rights of the limited partners
         do, however,  provide the Partnership with the "indirect ability ... to
         make decisions ... that have a significant effect on the success of the
         entity."  The  Partnership  recognized  the  potential  conflict in its
         conclusions under SOP 78-9 and FIN 46R related to the rights of limited
         partners,  but ultimately concluded that a substantially  greater level
         of influence over the operational and financial policies of an investee
         is necessary to achieve  "control"  under paragraph 10 of SOP 78-9 than
         is necessary to "have a significant  effect" under paragraph  5.b(1) of
         FIN 46R. The  Partnership  continues  to believe that the  existence of
         important  rights does not result in the  Partnership's  control of the
         local limited  partnerships,  but does provide the Partnership with the
         ability to have a significant effect on the local limited partnerships.

      2. Comment:  It is  unclear  from  your  response  how  you  reached  your
         conclusions  under  paragraph  5(c).  Please  explain  why you  believe
         substantially  all the activities of the local limited  partnerships do
         not  involve  and  are  not   conducted  on  behalf  of  you  and  NHP,
         collectively.  In  addition,  please  tell us what  other  parties  are
         involved in the activities and for whose benefit they are conducted.

          Response: An essential criterion for an entity to be considered a
          VIE  under  paragraph  5(c)  is  "substantially  all of  the  entity's
          activities  ...  either  involve  or are  conducted  on  behalf  of an
          investor that has  proportionately few voting rights." The Partnership
          does not  believe  and did not  intend to imply in its prior  response
          that   substantially   all  the   activities   of  the  local  limited
          partnerships  do not  involve and are not  conducted  on behalf of the
          Partnership and NHP,  collectively.  The Partnership believes that all
          partners in the local limited partnerships benefit from the activities
          of such  partnerships.  With the  exception of one investor who owns a
          one  percent  limited  partnership  interest in one of the three local
          limited partnerships, the Partnership has not identified parties other
          than the  Partnership  and NHP that are involved in the  activities of
          the local limited  partnerships  and has not identified  parties other
          than the  Partnership  and NHP for whom the  activities  of the  local
          limited partnerships are conducted.

                                    * * * * *

As requested by the Staff in its letter  dated April 13, 2005,  the  Partnership
again 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 of
                                    National Corporation for Housing
                                    Partnerships, the general partner of The
                                    National Housing Partnership, the general
                                    partner of National Housing Partnership
                                    Realty Fund I

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