SecProbe.io

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								March 23, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail
Larry G. Brady
Senior Vice President, Chief Financial Officer
The Greenbrier Companies, Inc.
One Centerpointe Drive, Suite 200
Lake Oswego, Oregon 97035

RE:  	The Greenbrier Companies, Inc. (the "Company")
      Form 10-K For the Year Ended August 31, 2004
      File No. 001-13146

Dear Mr. Brady:

We have reviewed your response letter dated March 3, 2005 and have
the following comments.  Where indicated, we think you should
revise
your future filings in response to these comments.  If you
disagree,
we will consider your explanation as to why our comments are not
applicable or a revision is unnecessary.  We also ask you to
provide
us with supplemental information so we may better understand your
disclosure.  Please be as detailed as necessary.  We look forward
to
working with you in these respects and welcome any questions you
may
have about any aspects of our review.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.  Pursuant to Rule
101(a)(3) of Regulation S-T, your response should be submitted in
electronic form, under the label "corresp" with a copy to the
staff.
After our review of your supplemental replies, we may have further
comments.  Please respond within fifteen (15) business days
Form 10-K For the Fiscal Year Ended August 31, 2004

Note 2- Significant Accounting Policies

Inventories, page 24

1. Refer to your response to our prior comment 8.  We note that
you
will disclose the excess or obsolete inventory valuation allowance
in
future filings.  We assume that you intend to provide a schedule
of
activity in the reserve for each period for which an income
statement
has been provided as contemplated by Rule 5-04 of Regulation S-X.
Please confirm, supplementally.

Maintenance Obligations, page 27

2. Refer to your response to our prior comment 11.  We note, from
your response, that you enter into maintenance agreements under
which
you contract to provide only the maintenance and repair of a group
of
railcars.  These contracts appear to be subject to the guidance
set
forth in FTB90-1.  If true, please further clarify whether and how
your accounting complies with this guidance.  Alternatively,
supplementally describe and support any accounting differences.
Your
response should be detailed and specific.

3. In your response to comment #12 you state that your warranty
reserve did not increase in correlation with sales, due to a
change
in your product mix.  Due to the significant increase in sales, it
seems that there would have to be a significant change in your
product mix, to warrant little or no change in your reserves.
Such a
significant change in your product mix should be discussed
extensively in your MD&A disclosures.  Therefore, please expand
your
MD&A disclosures to address this change and its effect on your
financial statements.  Additionally, please provide us with
details
showing the change in the product mix, for each of the fiscal
years
presented, and its effect on warranty reserves.  The detail should
provide us with an understanding of how much you accrue for each
type
of units and the change in your production units from year to
year.
Also please describe the duration and significant terms of your
warranties.

   You may contact Juan Migone at (202) 942-1771 or Margery Reich,
at
(202) 942-1839 if you have questions regarding comments on the
financial statements and related matters.  Please contact the
undersigned at (202) 942-1995 with any other questions.

								Sincerely,

								David R. Humphrey
      Branch Chief-Accountant

Via facsimile:  Larry G. Brady
		(503) 684-7553
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Larry G. Brady
The Greenbrier Companies, Inc.
March 23, 2005
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