SecProbe.io

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Mail Stop 3561

	August 24, 2005

Richard H. Walker, Jr., Esq.
South Jersey Gas Company
1 South Jersey Plaza
Folsom, New Jersey 08037

Re:	South Jersey Gas Company
	Registration Statement on Form S-3
	Filed July 22, 2005
	File No. 333-126822
      Form 10-K for the Fiscal Year Ended December 31, 2004
      Forms 10-Q for Fiscal Quarters Ended
      March 31, 2005 and June 30, 2005
      File No. 0-22211

Dear Mr. Walker:

      We have reviewed your response letter and have the following
comments.  Where indicated, we think you should revise your
document
in response to these comments.  If you disagree, we will consider
your explanation as to why our comment is inapplicable or a
revision
is unnecessary.  Please be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

      We welcome any questions you may have about our comments or
any
other aspect of our review.  Feel free to call us at the telephone
numbers listed at the end of this letter.

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

Note 1 - Summary of Significant Accounting Policies, page 30

Operating, page 31
1. We have read your response to our prior comment 2 of our letter
dated August 11, 2005.  You indicate that you have only excluded
the
results of the appliance services business since you transferred
that
business to a related entity effective September 1, 2004.  Tell us
why you did not remove the results of operations for all periods
presented.  See SFAS 141 paragraph D16.  Conversely, tell us why
you
did not classify the business as a discontinued operation in
accordance with SFAS 144 paragraphs 41 to 44.

Note 13 - Commitments and Contingencies, page 46
2. We have read your response to our prior comment 4 of our letter
dated August 11, 2005.  We note that the Cleanup Cost Cap
Insurance
Policy is limited to an aggregate payment amount of $50 million.
In
future filings, please disclose the limitation of the insurance
coverage.
3. In future filings, please provide a tabular presentation
showing
the beginning environmental liability, additions to the liability,
reductions, adjustments and the ending balance.
4. In future filings, please provide disaggregated disclosures
with
regard to the Bridgeton, Glassboro, Millville, and Salem sites.
We
note that these four sites represent, in aggregate, a significant
percentage of the accrued liability as well as the high end
estimate.
The disclosure should include the liability and high end estimate
for
these four sites either individually or in the aggregate.
Additionally, with respect to these sites please provide a more
detailed discussion of the stage of remediation, steps necessary
to
complete the remediation, as well as any significant risks to your
estimates.  See SOP 96-1 paragraphs 161 to 163.

* * *

        As appropriate, please amend your filings and respond to
these comments within 10 business days or tell us when you will
provide us with a response.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      Please contact Kurt Murao, Attorney Advisor, at (202) 551-
3338,
or Michael Moran, Accounting Branch Chief, at (202) 551-3841 if
you
have questions regarding the comments.

      Sincerely,

						H. Christopher Owings
      					Assistant Director

cc: 	Richard J. Busis, Esq.
	Cozen O`Connor
      Fax: (215) 701-2456

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Richard H. Walker, Jr., Esq.
South Jersey Gas Company
August 24, 2005
Page 1

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