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CORRESP
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      South Jersey Gas Company Confidential Correspondence

    [Letterhead
      of Cozen O’Connor]

              Richard
                J. Busis

              Direct
                Phone 215-665-2756

              Direct
                Fax 215-701-2456

              RBUSIS@COZEN.COM

              August
                19, 2005

              VIA
                EDGAR FILING

              Securities
                and Exchange Commission

              Division
                of Corporation Finance

              100
                F Street, N.E.

              Washington,
                D.C. 20549

              Mail
                Stop: 3561

              Attention:
                Mr. H. Christopher Owings, Assistant Director

              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 the Fiscal Quarters ended March 31, 2005 and June 30,
      2005

    File
      No. 0-22211

    Ladies
      and Gentlemen:

    On
      behalf
      of South Jersey Gas Company (the “Company”), we are hereby responding to the
      comments of the Commission staff as set forth in the letter of H. Christopher
      Owings, Assistant Director, dated August 11, 2005 with respect to the Company’s
      Registration Statement on Form S-3 filed July 22, 2005.

    For
      ease
      of reference, the responses have been numbered to correspond to the comments
      as
      numbered in the comment letter.

          Securities
            and Exchange Commission

          August
            19, 2005

          Page
            2

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

    Management’s
      Discussion & Analysis, page 12

    Commodity
      Market Risks, page 22

    1.
      The
      requested revisions will be made in future filings as required by Item 305
      of
      Regulation S-K.

    Note
      1—Summary of Significant Accounting Policies, page 30

    Operating
      Revenues, page 31

    2. The
      transfer of the appliance service business became effective as of September
      1,
      2004. Accordingly, the results of operations related to the appliance service
      business are included in the Company’s financial statements for each period
      through August 31, 2004. Beginning September 1, 2004, such results are not
      included. The removal of the appliance service business’ results of operations
      can be seen by the reduced appliance service business revenues for the year
      ended December 31, 2004 set forth in the revenue table entitled “Comparative
      Operating Statistics” on page 11 of the Company’s Form 10-K as such revenues
      were included only through August 31, 2004.

    Note
      11—Employee Benefit Plans, page 41

    3.  The
      "Amortization of Loss and Other" component of FAS 106 expense for fiscal years
      2004 and 2003 consists of the following (in thousands):

              2004

              2003

              Loss
                Amortization

              $

              284

              $

              454

              Prior
                Service Cost Amortization

              (154

              )

              (
                81

              )

                Total
                Amortization of Loss and Other

              $

              130

              $

              373

    The
      change in Loss Amortization was attributable to an asset gain during the period
      of January 1, 2003 to December 31, 2003 and assumption changes on January
      1, 2004, both of which lowered the unrecognized loss. These assumptions were
      summarized in the actuarial assumption table on page 44 of the Company’s Form
      10-K.

    The
      change in Prior Service Cost Amortization was primarily attributable to a plan
      amendment in 2004. This amendment placed caps on the amount of the premium
      the
      Company pays for all employees eligible for postretirement health care as
      described in the footnote on page 43 of the Company’s Form 10-K.

        Securities
          and Exchange Commission

        August
          19, 2005

        Page
          3

    Note
      13—Commitments and Contingencies, page 46

    4. [Confidential
      Treatment Requested by South Jersey Gas Company (item no. R-4) — The information
      contained in this response no. 4 has been submitted to the Commission
      supplementally pursuant to Rule 83 of the Freedom of Information
      Act.]

    General

    If
      you
      have any questions with regard to these responses, need further supplemental
      information or would like to discuss any of the matters covered by this letter,
      please contact me at (215) 665-2756 or my colleague Scott Brucker at (215)
      665-3710.

                    Sincerely,

                    COZEN
      O’CONNOR

                    /s/
      Richard J.
      Busis

                    BY:
      RICHARD J. BUSIS