SecProbe.io

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via facsimile and U.S. mail

Mr. Mark A. Hellerstein
President and Chief Financial Officer
St. Mary Land & Exploration
1776 Lincoln Street
Denver, CO 80203

Dear Mr. Hellerstein:

While conducting a limited review of your Annual Report on the
form
10-K we have the following questions related to your operations in
the Gulf of Mexico and other oil and gas producing areas:

1. Have you booked proved reserves without a production flow test
in
the deepwater Gulf of Mexico?  Have you booked proved reserves
without a production flow test in other areas?  Which areas?

2. If you have booked proved reserves without a production flow
test,
how long is the time from the reserve booking until first
production
in the shallow Gulf of Mexico, deepwater Gulf of Mexico and other
areas, if any.

3. What is the estimated cost to conduct a production flow test
from
your deepwater Gulf of Mexico properties?

4. When you perform production flow tests in the deepwater Gulf of
Mexico what is the average duration of the test?

5. What is the minimum amount of data that you require to book
proved
reserves in the Gulf of Mexico without a production flow test?
Other
areas?  Examples may be, but not limited to, types of open hole
logs,
seismic, whole cores, sidewall cores, MDT or RCI tests, DST`s,
pressure gradient surveys, number of penetrations, etc.

6. Do you consider this minimum amount of data to be the
equivalent
of a production flow test?  If so, why?  If not, why not?

Please understand that the purpose of our review process is to
assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  We look
forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect
of
our review.

Direct questions regarding these issues should be addressed to
either
petroleum engineers James Murphy (202-942-2939) or Ron Winfrey
(202-
942-1778.

Sincerely,

H. Roger Schwall

Assistant Director

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