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Mr. George F. Obsiek, Jr.

Branch Chief

Division of Corporation Finance

Securities and Exchange Commission

100 F Street NE

Washington, D.C. 20549-0305

U.S.A.

October 17, 2005

RE:       AES GENER INC.

            FORM 20-F FOR THE
FISCAL YEAR ENDED DECEMBER 31, 2004

            FILED JUNE 27,
2005

            FILE NUMBER
001-13210

Dear Mr. Obsiek:

This letter is in response to the Staff's comment letter dated September 30,
2005 (the "Comment Letter"), relating to our Annual Report on Form
20-F for the fiscal year ended December 31, 2004 (the "2004 20-F") of
AES Gener S.A. ("AES Gener", "we" or the
"Company").

Set forth below are the responses of the Company to the Staff's comments in
the Comment Letter. For ease of reference, each comment contained in the Comment
Letter is printed below in italics and is followed by the Company's response.

Form 20-F for Fiscal Year Ended December 31, 2004

Item 15. Controls and Procedures page 113

    Please revise your future disclosures regarding your description of
      disclosure controls and procedures maintained at your company to ensure it
      encompasses the entire definition of disclosure controls and procedures in
      Exchange Act Rules 13a-15(e) and 15d-15(e). Your current disclosure does
      not achieve this objective. Also confirm to us that your disclosures
      regarding the effectiveness of your disclosure controls and procedures are
      still accurate considering the entire definition of disclosure controls
      and procedures, or otherwise amend accordingly.

In future filings, AES Gener will revise its disclosures regarding its
description of disclosure controls and procedures maintained by the Company to
ensure that it encompasses the entire definition of disclosure controls and
procedures in Exchange Act Rules 13a-15(e) and 15d-15(e). We confirm to the
Staff that the Company's disclosures regarding the effectiveness of its
disclosure controls and procedures in our Form 20-F for the period ended
December 31, 2004 are still accurate considering the entire definition of
disclosure controls and procedures Exchange Act Rules 13a-15(e) and 15d-15(e).

Exhibits 12.1 and 12.2

  Please revise your Section 302 certifications in future filings to
    eliminate reference to the titles of your Chief Executive and Chief
    Financial officers in the introductory paragraph. Refer to Item 601(b) (31)
    of Regulation S-K. Please confirm to us that the inclusion of the titles was
    not intended to limit the capacity in which your executives signed the
    certifications, or revise your filing accordingly.

AES Gener will revise its Section 302 certifications in future filings to
eliminate reference to the titles of its Chief Executive and Chief Financial
officers in the introductory paragraph. We confirm to the Staff that the
inclusion of the titles of our Chief Executive and Chief Financial officers in
the introductory paragraph of the Section 302 certifications in our Form 20-F
for the period ended December 31, 2004 was not intended to limit the capacity in
which our executives signed the certifications.

Item 18. Financial Statements

Notes to Consolidated Financial Statements, page F-8

Note 19. Provisions. Page F-37

  Please explain the provision line item labeled "Conversion of
    convertible notes." Please also explain any Chilean vs. United States
    GAAP differences, if applicable.

The line item labeled "Conversion of convertible notes" refers to
the provision recorded by the Company for the premium payable to bondholders who
did not convert their bonds into shares before the bonds' maturity date. This
redemption premium resulted because the Company's convertible bonds were issued
at face value but redeemable at 105.625% of the principal amount at maturity.
Under Chilean GAAP, this provision was recognized through the effective interest
method over the term of the bonds and was based on the total amount of bonds
outstanding, which is consistent with U.S. GAAP.

Historically, we classified the provision within long-term liabilities under
Chilean and U.S. GAAP. We have re-evaluated this classification and have
determined that under U.S. GAAP, this provision should have been classified
within bonds payable rather than other non-current liabilities in our Form 20-F.
However, as the bonds were redeemed in 2004 and there was no effect on total
long-term liabilities in prior years as a result of this misclassification, we
do not believe that the effects of this misclassification are material.

No other differences exist in the accounting for the conversion option under
Chilean and U.S. GAAP because (1) the conversion option did not represent an
embedded derivative under the provisions of SFAS No. 133 as the option could not
be net settled, (2) there were no "make-whole" provisions or other
embedded features within the convertible bonds that should have been bifurcated
and accounted for as a separate derivative and (3) the conversion option was not
considered to be a beneficial conversion feature upon issuance.

Note 37. Differences between Chilean and United States Generally
Accepted Accounting Principles, page F-91

I. Reconciliation of Chilean GAAP to U.S. GAAP, Page F-91

(i) Investments in Related Companies (difference between cost and
equity method), page F-94

  You indicate that you do not consolidate Energen S.A. because the
    effect is not material. For United States GAAP purposes, materiality should
    not be the basis for consolidation assuming consolidation would otherwise be
    required. Please confirm to us, if true, that there are no material
    off-balance sheet transactions contingencies or other matters not reflected
    in your financial statements as a result of your decision to not consolidate
    Energen S.A. Tell us your basis in United States GAAP for not consolidating
    this entity. If you cannot support your policy under United States GAAP,
    please revise future filings to reflect the consolidation of Energen S.A.

Energen S.A. ("Energen") was formed in December 2000 for the
purpose of buying and selling electricity produced by third parties. The
company's business activities were identified as the import, export,
consignment, intermediary services and sale of electricity, or any other type of
administration or activity related to the generation, transmission or
distribution of electricity. In 2001, AES Gener decided to dissolve this company
and as a result, it was no longer consolidated in accordance with Chilean GAAP
although operations were continued. In the second half of 2005, Energen began to
sell gas to AES Gener's subsidiary Electrica Santiago S.A. As such, the decision
to dissolve this company was reversed and AES Gener now consolidates Energen
under Chilean GAAP.

As of December 31, 2004, Energen's total U.S. GAAP assets, liabilities and
results of operations were ThCh$4,684 (US$ 8,405), ThCh$9,883 (US$17,731) and
ThCh$(1,614) (US$ (2,896)), respectively, representing 0.0004%, 0.0089% and
(0.0002%) of AES Gener's total U.S. GAAP assets, liabilities and results of
operations, respectively. There are no material off-balance sheet transactions,
contingencies or other matters not reflected in our financial statements as a
result of our decision not to consolidate Energen. The Company will also
consolidate Energen in its U.S. GAAP financial statements in future filings.

(k) Effect of U.S. GAAP adjustments in related companies accounted for
under the equity method, page F-94

  Tell us whether you consolidate your investment in Empresa Electrica
    Guacolda S.A. (Guacolda) for United States GAAP purposes. In light of your
    50.00% stake in Guacolda we assume that you have evaluated the need to
    consolidate this entity under FIN 46 R.

The Company does not consolidate its investment in Guacolda for US GAAP
purposes. The Company accounts for this investment under APB No. 18 "The
Equity Method of Accounting for Investments in Common Stock". We also
affirm that we have evaluated the need to consolidate this entity under FIN 46R
and have concluded that consolidation is not necessary.

(x) Effects of Conforming with U.S. GAAP, page F-99

  You present United States GAAP condensed balance sheets and income
    statements. Please tell us if these condensed financial statements consider
    classification differences between Chi1ean and United States GAAP. In this
    regard we noted that you considered certain classification differences in
    your reconciliation of United States GAAP and Chilean GAAP net income on
    pages F-99 and F-100; however, there appears to be other classifications
    differences between Chilean and United States GAAP. For example, paragraph
    45 of SFAS 144 states that a "gain or loss recognized (on disposal of a
    long-lived asset) that is not a component of an entity shall be included in
    income from continuing operations. If a subtotal such as "income from
    operations" is presented it shall include the amounts of those gains or
    losses". Other potential classifications differences include, but are
    not limited to; the classification of amortization of intangible assets,
    pension and post-retirement development expenses and supplies and inventory
    write offs. Material classification differences should be discussed in your
    notes. Please tell us how you intend to revise your future filings. If your
    condensed United States GAAP financial statements do not reflect
    classification differences please tell us why you deem this appropriate.

The condensed U.S. GAAP financial statements presented consider
classification differences between Chilean and U.S. GAAP including those
referred to by the Staff. The principal classification differences between
Chilean and U.S. GAAP included in our filing relate to the following items:

  - Interest on notes receivable

  - Gain on the sale of fixed assets

  - Financial income (expense)

  - Gain (loss) on investments in related companies

  - Post-retirement pension plan and post retirement benefits

  - Research and development expenses

  - Supplies and inventories write-offs

  - Amortization of intangible assets

We will revise our future filings by including a discussion of the nature and
amounts of material classification differences reflected in our condensed
financial statements.

II. Additional Disclosure Requirements, page F-106

a(2) Diluted Earnings Per Share, page F-106

  Please tell us why you deemed it appropriate not to include the impact
    of your convertible bonds in your fiscal 2003 and 2004 diluted earnings per
    share calculation with reference to authoritative guidance. If the impact
    would have been anti-dilutive, as you indicate it was during 2002, please
    clarify. Refer to paragraphs 26-28 of SFAS 128. Please also tell us your
    consideration of the dilutive effect of your restricted stock issuances,
    stock option issuances and performances units with reference to
    authoritative guidance.

We inadvertently omitted to state that the impact of our convertible bonds
for fiscal years 2003 and 2004 would have been anti-dilutive. The first sentence
on page F-106 should have stated, "The calculation for December 31, 2002,
2003 and 2004 for the effect of the bond conversion has not been included as it
would have been anti-dilutive on the income from continuing operations
line." The convertible debt bonds were anti-dilutive because the interest
(net of tax) per common share obtainable on conversion exceeded basic EPS for
all periods presented. We will include such statement in our future filings.

AES Gener has not granted long term compensation ("LTC") awards to
its employees. The LTC plans disclosed in the Company's Form 20-F as of December
31, 2004, correspond to awards made by The AES Corporation, the controlling
shareholder of AES Gener, on February 12, 2003, May 1, 2003 and on February 4,
2004 to its and its subsidiaries' employees. These LTC plans, including stock
options and restricted stocks are accounted for under SFAS No. 123
"Accounting for Stock-Based Compensation," as amended by SFAS No. 148,
"Accounting for Stock-Based Compensation - Transition and Disclosure."
Additionally, the performance units granted under the plan are cash-settled and
are therefore accounted for under SFAS No. 5 "Accounting for
Contingencies".

In the reconciliation of net income from Chilean GAAP to U.S. GAAP, push down
accounting is applied to the stock options and restricted stock awards in order
to allocate the expense to the company in which the expense is incurred. In the
reconciliation of net income from Chilean GAAP to U.S. GAAP, adjustments are
made for the compensation expense booked under SFAS No. 123 as amended by SFAS
No. 148 as Chilean GAAP does not contemplate "pushdown" accounting for
such instruments. Such adjustments are also cumulatively recorded against
stockholders' equity.

It is important to note that the stock options and restricted stock awards
granted correspond to stock in The AES Corporation and not to stock in AES Gener.
As such, the awards do not have an effect on AES Gener's diluted earnings per
share. The capital increase executed by the Company in 2004 related to a primary
offering of AES Gener's common stock to existing shareholders and did not
include LTC awards such as restricted stock, stock option and performance units.

Performance units, which will be paid by AES Gener, reflect a cash liability
award under both Chilean and U.S. GAAP. The value of the performance unit awards
are not correlated with the performance of the stock of AES Corporation or AES
Gener.

No stock will ever be issued for the above-mentioned awards and as such, the
awards have no impact on the determination of diluted earnings per share.

In the calculation of basic earning per share, all awards of the LTC plan
have been included in the determination of net income in accordance with U.S.
GAAP.

(c) Segment Information, page F-109

  On page F-111 you reconcile your measure of segment profit to gross
    profit rather than to income before income taxes as required by paragraph
    32b of SFAS 131. Please revise your future filings accordingly.

In future filings, we will reconcile our segment profit to income before
taxes as required by paragraph 32b of SFAS 131.

(d) Investments in Related Companies, page F-112

  Based on review of page F-104 we note that your United States GAAP
    income before taxes for fiscal years 2003 and 2004 has decreased
    significantly as compared to fiscal 2002. As a result, your equity method
    earnings have become more significant to your pre-tax earnings, especially
    in 2003. Please tell us your consideration of Rule 3-09 of Regulation S-X,
    Separate Financial Statements of Subsidiaries Not Consolidated and 50
    Percent or Less Owned. In particular, it appears that your investment in
    Empresa Electrica Guacolda S.A. may be significant. Please note that United
    States GAAP amounts should be used to determine significance under Rule
    1-02(w) of Regulation S-X.

In order to determine whether our investment in Empresa Electrica Guacolda
S.A. is significant, we applied Rule 3-09 of Regulation S-X to the U.S. GAAP
amounts. Our analysis concluded that our investment in Empresa Electrica
Guacolda S.A. is not significant. In fiscal year 2004, the results were 7% under
the investment test and (0.88%) under the income test. In 2003, the results were
7% and (7%) under the investment and income tests, respectively.

However, it is important to note that we have accounted for our investment in
Empresa Electrica Guacolda S.A. (Guacolda) in two separate line items. The line
item "equity in earnings of affiliated companies'" of our condensed
income statement represents our equity earnings from this company under U.S.
GAAP, but the re-measurement effect on and for equity investments was separately
i