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PORTER & HEDGES, L.L.P.

    ATTORNEYS AND COUNSELORS AT LAW

    ROBERT G. REEDY

    1000 Main Street, 36TH FLOOR

    PARTNER

    HOUSTON, TEXAS 77002-6336

    Tel. Direct (713) 226-6674

    MAILING ADDRESS:

    Fax Direct (713) 226-6274

    TELECOPIER (713) 226-1331

    P. O. BOX 4744

    RREEDY@PORTERHEDGES.COM

    TELEPHONE (713) 226-6000

    HOUSTON, TX 77210-4744

May 3, 2005

003933/0002

Via EDGAR

Mr. H. Roger Schwall

Assistant Director

United States Securities and Exchange Commission

Division of Corporate Finance

450 Fifth Street, N.W.

Washington, D.C. 20549-0405

         Re:

    PetroQuest Energy, Inc.

    Form 10-K for the fiscal year ended December 31, 2004

    File No. 000-19020

Dear Mr. Schwall:

     This letter is in response to your letter dated April 26, 2005, to PetroQuest Energy, Inc.
(the “Company”) transmitting the comments of the staff (the “Staff”) of the U.S. Securities and
Exchange Commission (the “Commission”) relating to the above referenced Form 10-K. The numbered
paragraphs below correspond to the numbered comments in your letter.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
18

     Results of Operations, page 21

1. In response to your comment, the Company advises the Staff that it will revise future filings to
provide information about the quality and potential variability of the Company’s future earnings
and cash flow, so that readers can ascertain the likelihood that past performance is indicative of
future performance. Enclosed with this letter are excerpts from the Company’s Form 10-K for the
year ended December 31, 2004, marked to show the kind of disclosure that the Company anticipates
including in future filings to address the Staff’s comment. The substance of such disclosure will
of course depend on the facts and circumstances in existence at the time of each filing.

Mr. H. Roger Schwall

May 3, 2005

Page 2

Controls and Procedures, page 26

     Evaluation of Disclosure Controls and Procedures, page 26

2. In response to your comment, the Company advises the Staff that it will revise future filings to
clarify, if true at the time, that the Company’s officers have concluded that the Company’s
disclosure controls and procedures are also effective to ensure that information required to be
disclosed by the Company in the reports that it files or submits under the Exchange Act is
accumulated and communicated to the Company’s management, including the Chief Executive Officer and
the Chief Financial Officer, as appropriate to allow timely decisions regarding required
disclosure.

3. In response to your comment, the Company will revise future filings to delete the reference to
“in all material respects,” and will state, in clear and unqualified language, the conclusions
reached by the Company’s Chief Executive Officer and the Chief Financial Officer on the
effectiveness of the Company’s disclosure controls and procedures. The Company also supplementally
advises the Staff that the Company’s Chief Executive Officer and the Chief Financial Officer have
concluded that, as of December 31, 2004, the Company’s disclosure controls and procedures were
effective.

4. In response to your comment, the Company advises the Staff that the Company will revise future
filings to delete the reference to “significant” changes and will indicate if there have been any
changes in internal control over financial reporting.

Financial Statements, page F-1

     Note 1 — Organization and Summary of Significant Accounting Policies, page F-7

               Derivative Instruments, page F-9

5. In response to your comment, the Company advises the Staff that amounts reflected on the
Consolidated Statements of Income under the caption “Derivative Expense” represent the combined
impact of the settlements and mark-to-market adjustment of an ineffective gas hedging contract that
expired at the end of 2003 and the settlements and mark-to-market adjustment of an interest rate
swap contract that expired during 2004.

     The gas hedging contract was determined to be ineffective during 2003 due to a decline in
production from the specific field to which the derivative was designated. The interest rate swap
was never formally designated as a cash flow hedge and therefore did not qualify for hedge
accounting treatment. The Company will revise its disclosure in Management’s Discussion and
Analysis of Financial Condition and Results of Operations (“MD&A”) and in the notes to its
financial statements in future filings to state that derivative expense recorded in the periods
presented represents the impact of an ineffective gas derivative contract and an interest rate swap
that did not qualify for hedge accounting treatment. In addition, the Company will revise its

Mr. H. Roger Schwall

May 3, 2005

Page 3

disclosures in the notes to its financial statements in future filings to clearly identify the
components of derivative expense for the periods presented.

6. In response to your comment, the Company advises the Staff that amounts reflected on the
Consolidated Statements of Income under the caption “Derivative Expense” represent the combined
impact of the settlements and mark-to-market adjustment of an ineffective gas hedging contract and
the settlements and mark-to-market adjustment of an interest rate swap contract. As of December
31, 2004, both of these contracts had expired.

     The gas hedging contract was the only derivative instrument that required any accounting
recognition due to ineffectiveness. The Company will revise its disclosures in the notes to its
financial statements in future filings to clearly identify the components of derivative expense for
the periods presented.

7. In response to your comment, the Company advises the Staff that the gas hedging contract and
interest rate swap responsible for generating the unrealized gains and losses in the Company’s
financial statements expired at the end of 2003 and 2004, respectively. At December 31, 2004, all
of the Company’s derivative instruments qualified for hedge accounting treatment. Therefore, the
Company does not expect any unrealized gains or losses to be reclassified into earnings within the
next 12 months. The Company will include a statement to this effect in future filings.

8. In response to your comment, the Company advises the Staff that the Company discloses, in the
Critical Accounting Policies section of MD&A, that the Company’s hedges are specifically referenced
to the NYMEX index prices that the Company receives for its Gulf Coast Basin production. The
Company will disclose in future filings that it evaluates the effectiveness of its hedges at the
time it enters into the contracts and periodically over the life of the contracts by analyzing the
correlation between NYMEX index prices and the posted prices the Company receives from its Gulf
Coast Basin production. Through this analysis, the Company is able to conclude that there is a
high correlation between fluctuations in the prices that the Company will receive for its Gulf
Coast Basin production and the indexed prices at which the hedges will be settled.

Business, page 1

     2004 Operational Overview, page 2

9. In response to your comment, the Company advises the Staff that 26% of its proved reserves are
developed, non-producing and that the Company will disclose such information in future filings.

Mr. H. Roger Schwall

May 3, 2005

Page 4

               Gulf Coast Basin, page 2

10. In response to your comment, the Company advises the Staff that it will expand its disclosure
in future filings to include all of the requirements of Item 102 of Regulation S-K, such as
reserves, development and nature of its interest for the Ship Shoal 72 Field and other fields that
are significant to the Company’s operations.

Oil and Gas Reserve Information — Unaudited, page F-17

11. In response to your comment, the Company advises the Staff that in future filings it will
disclose that proved reserves constitute quantities that the Company is reasonably certain of
recovering in future years.

12. In response to your comment, the Company supplementally informs the Staff that during 2004, the
Company’s proved oil reserves declined by 13% and its proved gas reserves increased by 37%,
resulting in a total increase in its proved reserves of 22%. The decline in oil reserves was due
to the fact that 2004 oil reserve additions that did not offset 2004 oil production. The increase
in gas reserves was primarily due to the Company’s two acquisitions of natural gas properties in
Oklahoma. During 2004, the Company invested $25.6 million in Oklahoma to acquire 10.5 Bcfe of
proved reserves and to drill 17 wells with a 100% success rate. This drilling success yielded an
additional 6.2 Bcfe of proved reserves through discoveries. Overall, the Company had a 97%
drilling success rate during 2004 on 33 gross wells drilled. The Company advises the Staff that it
will expand its disclosure in the Oil and Gas Reserve Information section of future filings to
include information about significant changes to its reserves.

     In connection with the Company’s response to the Staff, the Company acknowledges that (i) it
is responsible for the adequacy and accuracy of the disclosure in this filing, (ii) Staff comments
or changes to disclosure in response to Staff comments do not foreclose the Commission from taking
any action with respect to this filing and (iii) 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.

     This letter has been prepared at the direction of, reviewed and approved by, the appropriate
senior officers of the Company. I hope the foregoing materials are responsive to the Staff’s
comments. Please call the undersigned at (713) 226-6674 with any additional comments or questions
you may have.

    Regards,

    /s/ Robert G. Reedy

    Robert G. Reedy

RGR/EJC

Enclosures

    cc:

    Mr. Mark A. Wojciechowski

    Ms. Jennifer Gallagher

    Mr. James Murphy