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September 12, 2005

United States Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, NW, Stop 4-5
Washington, DC   20549
USA

ATTENTION:  JILL S. DAVIS, BRANCH CHIEF

Dear Sirs and/or Mesdames:

RE:      Teck Cominco Limited
         Forms 40-F and 40-F/A1 for Fiscal Year Ended December 31, 2004
         Filed March 31, 2005 and April 1, 2005
         File No. 1-13184
         --------------------------------------------------------------

Thank you for your comment letter dated August 1, 2005 with respect to the above
noted filing. We have carefully considered your comments and have attempted to
address them in detail below. The headings and numbered responses set out below
correspond to the headings and numbered comments in your letter. Our responses
to your comments are as follows:

FORM 40-F FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004
CONSOLIDATED STATEMENTS OF CASH FLOW

1.       SEC Comment

"We note in your reconciliation of net earnings to net cash provided by
operating activities that you present two subtotals of net earnings and various
charges and credits above total net cash provided by operating activities. We
note the Illustrative example in CICA 1540, and that the subtotal presented does
not include net income; rather the presentation only includes "items not
affecting cash." Support your disclosure of these subtotals under Canadian GAAP
as there does not appear to be a provision within CICA 1540 for this
presentation."

     Response

     As you have observed, our reconciliation of net earnings to cash flow from
     operating activities provides a subtotal before changes to non-cash working
     capital items. We agree that this format differs from the illustrative
     example in section 1540 of the CICA handbook, which does not provide such a
     subtotal. We note, however, that in the preamble to the example, the CICA
     handbook states that "Other formats or levels of detail may be appropriate
     in other circumstances." The formats presented in the handbook are not
     requirements, but are used for illustration only.

                              TECK COMINCO LIMITED
                 600-200 BURRARD STREET, VANCOUVER, B.C. V6C 3L9
                 TEL: (604) 687-1117         FAX: (604) 687-6100

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     We believe the format that we have followed is appropriate. This format
     provides useful information to the reader by presenting the operating cash
     flow figures both before and after changes to non-cash working capital
     items such as receivables and inventory.

     Our review of other Canadian companies' presentation of cash flow from
     operating activities indicates that many companies, particularly those in
     the resource sector, have followed this format.

     We propose in the future to include a comment in our U.S. GAAP
     reconciliation note pointing out that the disclosure of this subtotal
     amount is not in conformity with U.S. GAAP, substantially as follows:

     "Under U.S. GAAP, cash flow from operations must be presented as the amount
     calculated after taking into effect the changes in non-cash working capital
     items. The disclosure of a subtotal referring to the amount of cash flow
     from operations before changes to working capital items is not permitted."

NOTE 2. SIGNIFICANT ACCOUNTING POLICIES
DERIVATIVES AND HEDGING ACTIVITIES

2.   SEC Comment

"Please expand on your disclosure to identify the line items in which you report
the fair values and the unrealized gains and losses of your derivative
instruments in the financial statements."

     Response

     In 2004, the fair values of derivative instruments which did not qualify
     for hedge accounting were reported in accounts receivable or accrued
     liabilities, as appropriate, and unrealized gains and losses were included
     in miscellaneous expense as a component of Other Income (Expense).

     The amounts in question were unrealized losses on copper forward sales
     contracts of $8.5 million offset by $4.3 million of gains on certain
     forward purchase commitments of zinc. In both cases these commitments did
     not qualify for hedge accounting. The net amount of $4.2 million was not
     presented as a separate line item as it was not material. This amount was
     included in miscellaneous expense of $7 million in Note 14.

     In the first two quarters of 2005, these mark-to-market gains and losses
     have been disclosed as a "non-hedge derivative losses" in a separate line
     item under Note 4 (entitled Other Income and Expense) of the interim
     financial statements. A copy of the note is attached for your information
     as Appendix A to this letter. We intend to continue with this disclosure in
     our quarterly and annual reports.

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We also propose to expand the disclosure on this item in our notes to the
financial statements at the year-end, under the heading "Significant Accounting
Policies", substantially as follows:

     "The fair values of the derivative instruments that do not qualify for
     hedge accounting are included in current receivables or current liabilities
     and the mark-to-market gains and losses are charged to earnings under the
     line item entitled Other Income and Expense."

PROPERTY, PLANT AND EQUIPMENT
(II)  MINERAL PROPERTIES AND DEFERRED COSTS

3.   SEC Comment

"We understand that you defer certain costs when they relate to specific
properties for which economically recoverable reserves as shown by an economic
study are believed to exist. Please tell us the nature of these costs, how you
determine the amount to defer, and the amount deferred as of each balance sheet
date. Please refer to the disclosure guidance included in the Appendix attached
to the minutes of the November 25, 2002 AICPA SEC Regulations Committee's
International Practices Task Force located at the AICPA website:
HTTP://WWW.AICPA.ORG/DOWNLOAD/BELT/2002_11_25.PDF and EITF 04-06 for US GAAP."

     Response

     We have reviewed the accounting and disclosure guidance included in the
     Appendix attached to the Minutes of the November 25, 2002 AICPA SEC
     Regulations Committee's International Practices Task Force, and noted the
     guidance with respect to reserves, acquisition costs and deferred costs. We
     have also reviewed EITF 04-06 for US GAAP.

     The deferred costs included in Mineral Properties in Note 6 to the 2004
     financial statements consist of the following items:

         1)   costs of land purchases (overlying surface rights);

         2)   acquisition costs for mineral properties;

         3)   fixed assets associated with dormant properties and certain
              non-operating assets;

         4)   construction in progress costs; and

         5)   miscellaneous deferred costs.

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September 12, 2005                                                   Page 4 of 9
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     A breakdown of these costs in tabular form is as follows:

                                                                 DECEMBER 31
                                                              2004        2003
                                                              ----        ----
                                                                 ($ million)

         Acquisition costs of mineral properties                44          64

         Land purchases (overlying surface rights)              12          12

         Fixed assets
                  Offices and research facilities                9           9
                  Equipment salvage values                      11          25
                                                                --         ---
                                                                20          34

         Miscellaneous deferred costs                            3           8

         Construction in Progress
                  Pend Oreille Mine                              -         116
                                                                --         ---
                                                                79         234
                                                                --         ---

     The development costs of the Pend Oreille mine, which were included in
     Mineral Properties in 2003, were transferred to Mines and Processing
     Facilities in 2004 when the property went into production.

     The amounts deferred in respect of acquisition costs are based on the
     actual costs of the relevant properties, provided that these amounts are
     judged to be recoverable either on a sale of the relevant property or
     through its future development. The company regularly assesses all fixed
     assets, including mineral properties, for impairment conditions which might
     indicate that their carrying value is not recoverable.

     Where exploration is conducted on a property where economically recoverable
     reserves as shown by an economic study are believed to exist, we defer
     those expenditures incurred to advance the relevant property and prove up
     additional reserves. Amounts to be deferred in respect of exploration
     expenditures are determined by reference to the relevant economic study,
     although there are no such costs currently deferred. In 2004, $42 million
     of exploration expenditures on properties where economically recoverable
     reserves are not believed to exist were expensed.

     The Mineral Properties line item does not include deferred stripping costs.
     Included in the Mines and Processing Facilities balances of $6,118 million
     and $6,110 million for 2004 and 2003 respectively were deferred stripping
     costs relating to coal mines of $17 million and $11 million respectively.
     These costs have not been separately identified on the grounds of
     immateriality.

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NOTE 15. INCOME AND RESOURCE TAXES
(C) TEMPORARY DIFFERENCES GIVING RISE TO FUTURE INCOME TAX ASSETS AND
LIABILITIES

4.   SEC Comment

"Please describe to us, in detail, the nature of the "timing of partnership
items" line item included in the tabular presentation of your future tax
liability."

     Response

     Under Canadian tax laws income earned in a partnership is taxable in the
     hands of each partner in the taxation year of that partner in which the
     fiscal year-end of the partnership falls. This situation can give rise to a
     timing difference and a provision for future income taxes.

     The company consolidates the earnings of Highland Valley Copper Partnership
     ("HVC"), which has a January 3 year-end, and Elk Valley Coal Partnership
     ("EVCP"), which has a January 31 year-end. The company's portion of
     earnings from these two partnerships in 2004 will be included in the
     company's taxable income in 2005. The amount of deferred taxes shown in the
     note relates to these two partnerships, with $228 million in respect of HVC
     and $45 million in respect of EVCP.

NOTE 18. COMMITMENTS AND CONTINGENCIES
(A) DERIVATIVES AND FINANCIAL INSTRUMENTS
FOOTNOTE (A)

5.   SEC Comment

"Please expand your disclosure to include the fair value of your zinc and lead
forward purchase commitments and explain to us why the related amounts have been
excluded from your tabular presentation."

     Response

     The fair value of the zinc and lead forward purchase commitments at
     December 31, 2004 was $9 million; of which $4 million of mark-to-market
     gains were taken into earnings for contracts that did not qualify for hedge
     accounting.

     These amounts were excluded from the tabular presentation because the
     commercial purpose of these contracts was different from that of the
     derivative hedge instruments presented in the table. These contracts were
     entered into to match fixed price future sales contracts for refined metals
     produced by the company's refinery operations. Any gains and losses on the
     forward purchase derivative instruments will be offset by corresponding
     gains and losses on fixed price forward sales commitments to customers. In
     contrast, derivative instruments presented in the table represent the
     company's hedging activities with respect to future mine production and
     power sales. Gains and losses on these instruments are intended to reduce
     the company's exposure to changes in future spot prices for the relevant
     commodities.

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     In future, we propose to present the quantities and amounts of these
     forward purchase derivative instruments together with the other derivative
     hedge instruments in the table, and expand our disclosure on these fixed
     forward purchase commitments by presenting the mark-to-market value and a
     footnote substantially as follows:

     "From time to time, certain customers request to purchase refined zinc and
     lead at fixed forward prices from the company's smelter and refinery
     operations. The forward purchase commitments for zinc and lead are matched
     to the fixed price sales commitments to customers. Any gains or losses from
     these forward purchase commitments will be offset by similar gains or
     losses on the fixed price sales commitments."

FOOTNOTE (C)

6.   SEC Comment

"Please expand on your disclosure to clearly explain why you are unable to apply
hedge accounting to the copper forward sales contracts."

     Response

     The company sells copper concentrates to its customers at prices based on
     the monthly averages of quoted prices for the contained metals. From time
     to time, in order to reduce its exposure to copper price fluctuations, the
     company enters into fixed-price forward sales contracts. Copper
     concentrates also contain other metals such as silver and gold. In periods
     when copper prices remain relatively unchanged, a change in value in the
     precious metals content can form a large proportion of the change in the
     value of the concentrate. While the copper forward sales contracts
     constitute an effective economic hedge for the copper content, when matched
     against the potential change in value of the concentrates, the arrangements
     are not sufficiently effective to meet the criteria for hedge accounting.

     We propose to expand our disclosure in the footnote to explain why copper
     forward sales do not qualify for hedge accounting, substantially as
     follows:

     "Copper forward sales contracts do not qualify for hedge accounting because
     when matched against the potential change in value of the concentrates,
     hedging only the copper content in the copper concentrates may not result
     in a sufficiently effective hedge against the value of the concentrates
     sold to customers."

NOTE 20. GENERALLY ACCEPTED ACCOUNTING PRI