SecProbe.io

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<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
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Mail Stop 3561

 					October 17, 2005

Mr. Patrick J. Goodman
Senior Vice President and Chief Financial Officer
MidAmerican Energy Holdings Company
P.O. Box 657
Des Moines, IA 50303

	Re:	MidAmerican Energy Holdings Company
		Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 1, 2005
		Forms 10-Q for Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
		File No. 1-14881
		MidAmerican Funding LLC
		Form 10-K for Fiscal Year Ended December 31, 2004
		Filed February 28, 2005
		Forms 10-Q for Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
		File No. 333-90553
		MidAmerican Energy Company
		Form 10-K for Fiscal Year Ended December 31, 2004
		Filed February 28, 2005
		Forms 10-Q for Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
		File No. 333-15387

Dear Mr. Goodman:

      We reviewed your responses to our comments on the above
referenced filings as set forth in your letter dated September 27,
2005.  Our review resulted in the following additional comment.

MidAmerican Energy Holdings Company

Form 10-K for Fiscal Year Ended December 31, 2004

Note 2. Summary of Significant Accounting Policies, page 63

1. Please refer to comment 4 in our letter dated September 13,
2005
and address the following additional comments:
o We note the capacity fees associated with the Upper Mahiao and
Mahanagdong Projects are subject to semi-annual adjustments
pursuant
to changes in contractually specified price indices.  Please tell
us
and revise to disclose the contractually specified price indices
on
which the adjustments are based.  Also explain your consideration
of
whether this provision in the contracts represents an embedded
derivative requiring separation from the host contract, as
contemplated in paragraph 12 of SFAS 133.
o Explain in more detail how you determined to classify the Leyte
and
Casecnan projects/leases as operating, as opposed to sales-type
leases.  In particular, based on your reference to paragraph 8 of
SFAS 13, we assume you concluded the leases do not represent real
estate leases.  Please tell us how you made this determination
and,
in this regard, whether you own the land underlying the
facilities.
o Given that you classified the projects/leases as operating
leases
due to "significant uncertainty" regarding the
collectibility/realizability of revenues, please tell us why you
believe it is appropriate to record revenues under these
projects/leases prior to collection.  Refer, for example, to SAB
Topic 13.A.1., which indicates that revenues are not considered
realizable until collectibility is "reasonably assured."  To help
us
understand the inception to date difference between revenues
recorded
and amounts collected from your customers, please tell us the
amount
of billed and unbilled receivables under these particular
contracts/leases, as well as the amount of any related reserves.
o Expand your proposed revenue recognition disclosure to explain
why
the Leyte and Casecnan projects/leases are classified as operating
leases, despite the fact that ownership of the facilities under
lease
transfers to the customer at the end of the respective cooperation
periods.
o Expand your proposed revenue recognition disclosure to clarify
that
revenues for the Casecnan Project are recorded as billed rather
than
on a straight line basis.  Also disclose why your method deviates
from the straight line method that is generally prescribed by SFAS
13.
o Revise your proposed revenue recognition disclosure to clarify
how
you applied EITF 00-21 to the lease and non-lease (service
contract)
components of the arrangements.   In this regard, reference is
made
to your proposed disclosure that "[t]he project agreements are
accounted for as arrangements that contain both an operating lease
and a service contract to operate the projects."
o Revise your MD&A to discuss in a reasonable amount of detail the
uncertainties surrounding collections under these projects/leases,
including the reasonably likely effects on your results of
operations
and financial condition of non-performance by your customer(s).

*    *    *    *

      As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter that keys your responses to our
comment
and provides any requested information.  Detailed cover letters
greatly facilitate our review.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

      You may contact Staff Accountant Sarah Goldberg at (202)
551-
3340, or in her absence, Robyn Manuel at (202) 551-3823 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3843 with any other
questions.

								Sincerely,

								George F. Ohsiek, Jr.
								Branch Chief

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Mr. Goodman
MidAmerican Energy Holdings Company
October 17, 2005
Page 1 of 3

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