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CORRESP
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      South Jersey Gas Company Correspondence

    [Letterhead
      of Cozen O’Connor]

              Richard
                J. Busis

              Direct
                Phone 215-665-2756

              Direct
                Fax 215-701-2456

              RBUSIS@COZEN.COM

              August
                29, 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 24, 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
            29, 2005

          Page
            2

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

    Note
      1 - Summary of Significant Accounting Policies, page
      30

    Operating
      Revenues, page 31

    1. During
      the Company’s phone conference with Michael Moran, Accounting Branch Chief, on
      August 25, 2005, the staff agreed that only the last sentence of this comment
      needs to be addressed further.

    Accordingly,
      the staff has inquired as to why the Company did not classify appliance service
      related results as a discontinued operation. The Company based its decision
      for
      not treating its appliance service activities as a discontinued operation on
      two
      principal factors: (a) the immateriality of the activity in relation to the
      Company’s overall business; and (b) the Company does not believe these
      activities meet the definition of an operating segment or component as defined
      by SFAS 144.

    The
      first
      reason that appliance service results were not treated as a discontinued
      operation was the immaterial nature of that activity. The Company’s appliance
      service activities were viewed by the Company as an ancillary revenue generating
      activity of the overall business conducted by the Company. The results of the
      Company’s appliance service activities were incidental to the Company’s overall
      business and represented only approximately 1.8% and 2.0% of the Company’s total
      revenue for the years ended December 31, 2003 and 2002, respectively. Total
      appliance service related assets at the time the business was transferred
      represented only 0.7% of the Company’s total assets. The appliance service
      activity was clearly immaterial to the overall business of the Company.

    Secondly,
      SFAS 144 paragraph 41 indicates that:

    “For
      purposes of this statement, a component of an entity comprises operations and
      cash flows that can be clearly distinguished, operationally and for financial
      reporting purposes, from the rest of the entity. A component of an entity may
      be
      a reportable segment or an operating segment (as those terms are defined in
      paragraph 10 of Statement 131), a reporting unit, a subsidiary, or an asset
      group (as that term is defined in paragraph 4).”

    The
      operations and cash flows of the Company’s appliance service activity were not
      clearly distinguished, operationally and for financial reporting purposes,
      from
      the rest of the Company, and appliance service was not treated as a separate
      operating segment, component, distinct reporting unit, subsidiary or asset
      group
      of the Company. The business activity of the appliance service business was
      in
      fact an integrated part of the overall business of the Company. For example,
      although certain revenue and expense information was collected and used
      internally to monitor the profitability of the appliance service activities
      prior to the transfer, no balance sheets or separate cash flow information
      was
      collected or

        Securities
          and Exchange Commission

        August
          29, 2005

        Page
          3

    reported
      in order to manage the activity. In addition, the Company charged customers
      for
      all products and services provided on one bill, and customer payments were
      not
      segregated by the Company with respect to the sale of a particular product
      or
      the provision of appliance services. All customer payments were collected
      together in one common Company account. Further evidence of the integrated
      operations of the appliance service activities can be seen by the fact that
      the
      Company did not employ separate appliance service technicians, but instead
      employed a workforce that performed services related to the appliance service
      activities as well as the other utility operations and maintenance activities
      of
      the Company. Finally, vehicles and equipment used to perform appliance service
      functions were also used for a variety of services in support of the Company’s
      gas distribution activities. In fact, an important factor in the Company’s
      decision to move the appliance service activities outside of the utility was
      the
      desire to begin managing the business as a distinct segment. The transfer date
      of September 1, 2004 was determined by the New Jersey BPU as part of their
      approval to permit the transfer to occur.

    The
      foregoing demonstrates that the appliance service activity conducted by the
      Company was not distinguished from the rest of the Company as a discreet
      business or operating segment, reporting unit or asset group. Accordingly,
      the
      Company did not treat the transfer of the appliance service activity as a
      discontinued operation under SFAS 144 because, prior to the transfer, the
      Company did not deem it to be a component or operating segment as defined by
      SFAS 131 or SFAS 144. Furthermore, the Company does not believe that such
      treatment or disclosure was necessary due to the immaterial nature of the
      appliance service activities as compared to the total revenues and total assets
      of the Company.

    Note
      13 - Commitments and Contingencies, page 46

    2. The
      requested disclosure will be made in future filings.

    3. The
      requested disclosure will be made in future filings.

    4. The
      Company will disclose in future filings the aggregate accrued liability and
      the
      aggregate high end estimate of the cost to remediate the four referenced sites,
      without making specific reference to such sites. Additionally, the Company
      will
      provide in future filings more detailed disclosure relating to the stage of
      remediation, the steps necessary to complete the remediation, as well as risks
      to the Company’s remediation estimates with respect to each of the four
      referenced sites, without making specific reference to such sites.

        Securities
          and Exchange Commission

        August
          29, 2005

        Page
          4

    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

      BY: RICHARD J.
      BUSIS