SecProbe.io

<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
								December 12, 2005

Mr. David H. Brett
President and Chief Executive Officer
Cusac Gold Mines Ltd.
911-470 Granville Street
Vancouver, B.C. V6C 1V5

	Re:	Cusac Gold Mines Ltd.
		Form 20-F for the Fiscal Year Ended December 31, 2004
Filed July 14, 2005
Response letter dated November 7, 2005
		File No. 000-13548

Dear Mr. Brett:

      We have reviewed your response letter and filings and have
the
following comments.  We have limited our review to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

General

1. In your next response, please provide the representations
regarding the adequacy and accuracy of your disclosures requested
at
the end of this letter.

Form 20-F for the Fiscal Year Ended December 31, 2004

General

2. We believe it will be necessary to revise your Form 20-F to
include all of the proposed disclosure revisions that you provided
in
your letter dated November 7, 2005, and any additional disclosures
necessary to comply with the comments below.

Consolidated Statements of Cash Flows, page 6

3. In response to prior comment 4, you propose revising the
Financing
activities portion of the Statements of Cash Flows to increase the
amounts previously reported for Share capital and subscriptions
received, net; and to add a separate line item labeled as Proceeds
from flow-through shares, net of future income tax recovery,
offsetting the increases noted above for 2003 and 2002, but
exceeding
such increase for 2004, with the result of changing your reported
financing cash flow for 2004. It would be helpful to further
revise
your table to separately present the cash proceeds from flow-
through
shares issued and warrants and options exercised.  In addition,
disclose the reasons you believe cash received from the issuance
of
flow through shares should be presented net of income tax
recovery,
so it is clear how this future activity impacts cash proceeds
currently.  Please include error correction disclosures to address
the change in financing cash flows.

4. In the table presenting transactions that did not result in
cash
flows at the bottom of the Statements of Cash Flows, you include
an
item identified as Issuance of flow-through shares.  Expand your
disclosure to explain how the activity associated with these
amounts
differs from that associated with the amount of cash received from
issuance of flow-through shares presented as an investing activity
in
your Statements of Cash Flows.

Note 4 - Resource Properties, page 14

5. In your response to comment 8, you advised of some measures
utilized in your impairment analyses related to your Table
Mountain
Gold Mine for 2004 and 2003, while stating that the analysis
conducted in 2004 was "fairly similar" to the analysis performed
in
2001 - 2003.  However, we were anticipating the detailed
calculations
that you performed in arriving at the estimated fair value of
assets,
including a discussion of the various assumptions that you have
made
with regard to the inputs.  We expect that your analyses would
need
to address the current status of the mine, production capacity,
any
capital improvements or further development required, and the
propriety of the costs and prices assumed.  We will continue our
review of your impairment testing once we have received the
balance
of your reply.  Please contact us by telephone if you require
further
assistance or clarification.

Engineering Comments

Planned Work Program, page 25

6. The fourth paragraph describes the results of the Pre-
feasibility
study.  The ore reserves are stated as contained ounces and this
estimate may be confused with estimated production & revenue.
This
possibility is demonstrated within the last bullet point, where
the
amortization costs are calculated based on the contained ounces.
Please restate the contained ounces as recovered ounces, state
clearly estimated metallurgical recoveries, and recalculate the
amortization.

Closing Comments

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please understand that we may have
additional
comments after reviewing your amendment and responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

      You may contact Mark A. Wojciechowski at (202) 551-3759 or,
in
his absence, Karl Hiller at (202) 551-3686 if you have questions
regarding comments on the financial statements and related
matters.
You may contact George K. Schuler, Mining Engineer, at (202) 551-
3718
if you have questions related to engineering issues and related
disclosures.  Please contact me at (202) 551-3740 with any other
questions.

								Sincerely,

								H. Roger Schwall
								Assistant Director

??

??

??

??

Mr. David H. Brett
Cusac Gold Mines Ltd.
December 12, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

</TEXT>
</DOCUMENT>