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                              SEWARD & KISSEL LLP
                             ONE BATTERY PARK PLAZA
                            NEW YORK, NEW YORK 10004

                           TELEPHONE: (212) 574-1200
                           FACSIMILE: (212) 480-8421
                                 www.sewkis.com

                                                                 August 12, 2005

Via EDGAR

Mr. David P. Humphrey
Division of Corporate Finance
Securities and Exchange Commission
Mail Stop 3561
100 F Street, N.E.
Washington, D.C. 20549

     Re:  Excel Maritime Carriers Ltd. Form 20-F for Fiscal Year Ended
          December 31, 2004, Filed June 29, 2005 (File No. 1-10137)
          ---------------------------------------------------------

Dear Mr. Humphrey:

          This letter responds to comments of the staff (the "Staff") of the
Securities and Exchange Commission (the "SEC") to the Annual Report on Form 20-F
for the fiscal year ended December 31, 2004 ("Form 20-F") of Excel Maritime
Carriers Ltd. (the "Company") filed June 29, 2005, as provided in a letter to
Christopher J. Georgakis, the Company's President and Chief Executive Officer,
dated August 1, 2005.

          This letter sets forth the Company's responses to the Staff's
comments. For your convenience, the Staff's comments have been restated in their
entirety, with the responses to each comment set forth immediately under the
comment.

Operating and Financial Review and Prospects
--------------------------------------------

Comment:  From disclosure in your filing, it appears all of your acquired
          vessels, including those acquired subsequent to December 31, 2004, are
          second hand vessels that are revenue producing assets. Please clarify,
          supplementally and in your filings, whether any of the newly acquired
          vessels have associated voyage or time charter agreements under
          contract with the Selling entity that you will assume, and whether or
          not the operation of these second hand vessels were used by the
          Selling entity in a similar commercial and technical management
          structure as your. Please note that we would consider each such vessel
          acquisition separately on a facts and circumstances basis before
          concluding that an asset had been acquired, as opposed to a business.

Response: With the exception of vessel M/V "Powerful" all of the Company's
          vessels have been acquired free of any time or voyage charter
          agreements. The M/V "Powerful" was acquired on April 12, 2005, with an
          associated time charter agreement, at the then prevailing market
          rates.

          Consistent with shipping industry practice, the Company has concluded
          that the acquisition of the secondhand vessels (whether acquired with
          or without charter) prior or subsequent to December 31, 2004, are not,
          in each case, acquisitions of a "business" under Rule 11-01(d) of
          Regulation S-X.

          In arriving at a conclusion that the acquisition of these vessels,
          individually or in the aggregate, would not constitute acquisitions of
          one or more businesses, the Company considered and applied the factors
          set forth in Rule 11-01(d) of Regulation S-X. In performing an
          analysis pursuant to Rule 11-01(d), the Company considered (1) whether
          the nature of the revenue producing activities will remain generally
          the same as before the acquisitions; or (2) whether any of the
          attributes remain after the transaction: (i) physical facilities, (ii)
          employee base, (iii) market distribution system, (iv) sales force, (v)
          customer base, (vi) operating rights, (vii) production techniques or
          (viii) trade names.

          As is customary in the shipping industry, each of the acquired
          secondhand vessels was individually acquired pursuant to a memorandum
          of agreement (the standard form of ship sale contract used in the
          shipping industry). The standard memorandum of agreement, among other
          things, provides the Company with the right to inspect the physical
          condition of the vessel and examine the classification society
          records. The agreement does not give the Company the right to inspect
          or receive any historical financial and operating data of the vessel,
          since the seller is not transferring any assets or liabilities,
          associated with the vessel's previous operations, other than the
          physical delivery of the vessel. The Company does not perform any
          historical financial due diligence in respect of the secondhand
          vessels it has acquired. The Company prior to taking delivery of the
          vessel will require the seller to evidence that the vessel is free of
          any encumbrances. The Company's decision to acquire a vessel is based
          on its assessment of future market opportunities and the ability of
          its managers to employ the vessel in favorable chartering
          arrangements. In addition, the technical management agreement between
          the seller's technical manager and the seller is automatically
          terminated and the vessel's trading certificates are revoked by its
          flag state following a change in ownership. Therefore, the Company
          does not consider that historical information is material to its
          decision to make any particular acquisitions nor does it believe that
          such information would be helpful to investors of its common stock in
          assessing the Company's future financial results or profitability.

          As already mentioned, in April 2005, the Company acquired one vessel
          with an assumed time charter. In cases when a vessel is under a time
          charter arrangement and the Company agrees to assume the charter, the
          vessel cannot be acquired without the charterer's consent and the
          Company's entering into a separate arrangement with the charterer to
          assume the time charter, which may include the agreement of the
          charterer to change the vessel's flag and commercial and technical
          manager. In the case of the M/V "Powerful" the time charter was
          assumed by the Company as the new owner with the charterer's consent,
          as specified in the related Addendum to the existing charter contract
          at the time of the purchase of that vessel. The Addendum was executed
          by all three relevant parties, namely, the seller, the buyer and the
          charterer.

          In all acquisitions of both charter-free vessels and vessels with
          assumed time charters, the Company undertakes the responsibility for
          the commercial and technical management of such vessels. The Company
          believes that the change in commercial and technical management is
          significant due to the unique configuration and characteristics
          related to: (i) its commercial management (including with respect to,
          among other things, its customer base, industry contacts, trades,
          routes, land-based personnel, geographic and commercial focus,
          business strategy, commercial strengths and any actual or perceived
          weaknesses), since the nature of the revenue generating activities of
          each acquired vessel has or will upon expiration of assumed time
          charters, materially change; and (ii) its technical management
          (including with respect to, among other things, its specific crews,
          insurance coverage, maintenance and repair decisions and financial
          structure), the nature of each acquired vessel's cost structure has or
          will materially change. Therefore, the Company believes that the
          overall operational structure of the vessel has or will change and,
          together with the change in the commercial and technical management of
          the vessels, the business attributes stemming from each such acquired
          vessel's prior operation under the previous owner would not be
          relevant to the Company or to investors in its common stock.

          In the Company's future filings, it will disclose whether any newly
          acquired vessels have associated voyage or time charter agreements
          under contract with the seller that will be assumed, and whether or
          not the operation of these second hand vessels were used by the
          sellers in a similar commercial and technical management structure as
          the Company's, to the extent known.

Results of Operations
---------------------

Fiscal Year Ended December 31, 2004
Compared to Fiscal Year Ended December 31, 2003
-----------------------------------------------

Comment:  We note the substantial increase in your revenues during fiscal 2004
          as compared to fiscal 2003. We further note that there was no
          correlating increase in voyage costs or vessel operating expenses. In
          future filings, please further describe in detail why revenue, by
          charter type, increased with no offsetting increase in the related
          costs. Disclose the percentage or amount of your revenue generated
          from time charters, spot charters, and voyage charters for each year
          in which statements of income are presented and further disclose why
          each charter generated more or less revenue than the other during the
          period. Disclose in this section the number of charter hires during
          the period for each revenue charter type as compared to the prior
          year. Also, explain which drybulk cargoes contributed to the increased
          shipments in Asia and China and, explain the factors that caused the
          average TCE rate to increase 119.6% in the current year from this
          growth.

Response: The substantial increase in the Company's revenues during fiscal 2004
          as compared to fiscal 2003 with no correlating increase in voyage
          costs or vessel operating expenses was achieved, in large part, due to
          the increase of charter rates to historic highs in 2004.

          The Company reports financial information and evaluates its operations
          by charter revenues and not by the type of vessel, length of vessel
          employment or type of charter. The Company's management reviews
          operating results of its fleet, and the Company operates in one
          reportable segment. The Company will report in future filings the
          percentages of revenues derived from time charters and from voyage
          charters and the percent of operating days that were covered by time
          charters and voyage charters. The Company will also report to the
          extent changes in its revenues and voyage expenses result from the mix
          of its time and voyage charters.

          In 2005, the Company has increased the size of its fleet significantly
          and has experienced a resulting increase in vessel operating costs. At
          the same time, charter rates have receded from their historically high
          levels in the first part of 2005. In future filings, the Company will
          discuss these facts and their effects and consequences in detail.

          In the Form 20-F, under "The International Dry Bulk Shipping Market",
          the Company explains that heavy demand for major bulk commodities,
          such as iron ore and coal, from the Far East region and more
          specifically from China, spurred by the growth of China's economy at a
          record pace of almost 9%, contributed to the increased shipments in
          Asia and China. The Company will disclose this in future filings under
          "Results of Operations" to the extent applicable. Likewise, the
          Company will discuss the factors that caused the average TCE rate to
          increase 119.6% in the current year from this growth.

Summary of Contractual Obligations
----------------------------------

Comment:  Due to the significant amount of debt incurred to finance the
          acquisition of your newly acquired vessels, we believe you should
          include scheduled interest payments in the table or, in the
          alternative, include additional disclosure regarding interest payments
          in a footnote to the table. See Section IV.A of FR-72 for guidance.
          Please include in future filings.

Response: The Company will include in future filings scheduled interest payments
          in a table or, in the alternative, additional disclosure regarding
          interest payments in a footnote to the table.

Financial Statements
--------------------

Note 6. Vessels, net
--------------------

Comment:  We see that you entered into an agreement to sell Petalis in December
          2004. Under SFAS 144, a disposal group to be sold should be classified
          as held for sale in the period specified by paragraph 30 of the
          statement. As each vessel appears to be held by a separate subsidiary,
          supplementally explain why you have not reported the results of
          operations of Petalis in discontinued operations in accordance with
          paragraphs 41 through 43 of SFAS 144. We may have further comment upon
          review of your response.

Response: In late December 2004 the Company agreed, subject to certain
          conditions, to sell the vessel "Petalis" to an unrelated third party.
          According to the terms of the related Memorandum of Agreement ("MOA"),
          (a) the vessel was supposed to be delivered to the buyer charter free
          and free of cargo with expected time of delivery between January 20
          and March 15, 2005, (b) the transfer of the vessel's ownership would
          be subject to the results of an underwater inspection, according to
          which the seller would give the buyer a notice of readiness of
          delivery and (c) if the seller failed to give notice of readiness or
          failed to be ready to validly complete a legal transfer of the
          vessel's ownership by March15, 2005, the buyer had the option of
          canceling the agreement.

          At the time of the conclusion of the MOA, the "Petalis" was employed
          under a time charter agreement. Consequently, the Company did not
          intend to deliver the vessel to the buyer until after the expiration
          of the time charter agreement on March 7, 2005. The delay in the
          timing of the transfer of the vessel imposed by the Company as seller
          demonstrated that the vessel was not available for immediate sale.

          Based on the above, and similar to Example 6 of Appendix A to SFAS 144
          (paragraph A17b), the "held for sale" criterion discussed under SFAS
          144, paragraph 30(b) would not be met until the operations of the
          vessel ceased. That event would not occur until the vessel's existing
          time charter expired in March 2005, even though a firm purchase
          commitment for the future transfer of the vessel was signed in
          December 2004.

          Accordingly, the Company has concluded that the vessel "Petalis"
          should not be classified as held for sale, since all criteria required
          by SFAS 144, paragraph 30, for classifying the "Petalis" as held for
          sale at December 31, 2004, were not met.

          Furthermore, the Company advises the Staff that the decision for the
          sale of the "Petalis" was made, as discussed in the related press
          release dated December 22, 2004, within the context o