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      PMA Correspondence 9-19-2005

    [LETTERHEAD
      OF PMA CAPITAL CORPORATION]

              September
                22, 2005

    Via
      EDGAR, Facsimile and Overnight Carrier

                United
                  States Securities and Exchange Commission

                Division
                  of Corporation Finance

                100
                  F Street, N.E.

                Washington,
                  D.C. 20549

                Attention:
                  Jim B. Rosenberg, Senior Assistant Chief Accountant

                  Re:

                  PMA
                    Capital Corporation (the “Company”)
                    Form
                      10-K for the fiscal year ended December 31, 2004

                    Forms
                      10-Q for the periods ended March 31, 2005 and June 30,
                      2005

                    File
                      No. 000-22761

      Ladies
        and Gentlemen:

      This
        letter responds to the Staff’s comment letter dated September 6, 2005, regarding
        the Company’s Annual Report on Form 10-K for the fiscal year ended December 31,
        2004 (the “2004 Form 10-K”) and the Quarterly Reports on Form 10-Q for the
        periods ended March 31, 2005 (the “March 10-Q”) and June 30, 2005 (the “June
        10-Q”).

      Before
        responding to your comments, the Company wants you to know that on September
        16,
        2005, it filed Amendment No. 1 to its 2004 Form 10-K for the sole purpose
        of
        filing three years of separate audited financial statements for certain of
        the
        Company’s operating subsidiaries, whose securities are pledged as collateral for
        the Company’s $99.1 million aggregate principal amount of its 6.50% Senior
        Secured Convertible Debentures due 2022.

      For
        your
        convenience, each of the Staff’s comments applicable to the 2004 Form 10-K, the
        March 10-Q and June 10-Q has been reproduced, followed by the Company’s response
        to each comment. The Company appreciates the Staff’s comments and confirms that,
        as set forth below, in preparing its future filings, it will do so in a manner
        that is reflective of its responses in this letter. The Company respectfully
        believes, however, that any amendment to its 2004 Form 10-K, March 10-Q or
        June
        10-Q is not necessary since the comments to the Company’s MD&A are largely
        designed to suggest that the Company make more detailed disclosure in certain
        areas. However, as explained below, the Company believes that various sections
        of its 2004 periodic reports already contain significant detailed disclosure
        addressing the topics which are the subject of the Staff’s comments.
        Accordingly, the Company does not believe that amending the filed reports
        would
        provide new, material information or materially benefit investors.

        United
          States Securities and Exchange
          Commission

        September
          22, 2005

        Page
          2

      Form
        10-K for the year ended December 31, 2004

      Item
        7. Management’s Discussion and Analysis of Financial Condition and Results ....
        page 18

      Liquidity
        and Capital Resources, page 48

                1.

                Please
                  include in MD&A a more robust discussion of the expected effect that
                  cash used in operating activities will have on future financial
                  position,
                  operations and liquidity. In the disclosure, also include a discussion
                  of
                  your asset/liability management process including the change to
                  the
                  duration of your investment portfolio described on page 36. Disclose
                  whether there are any significant variations between the premiums
                  collected (or to be collected), the maturities of your investments
                  and the
                  expected payment of your loss reserves. Include a discussion of
                  the impact
                  of selling securities before anticipated or the use of credit facilities
                  to pay for policy liabilities will have on your future financial
                  position,
                  operations and liquidity.

      RESPONSE:
        The
        Company confirms that it will supplement its current disclosure prospectively,
        beginning with the Company’s Quarterly Report on Form 10-Q for the three and
        nine month periods ending September 30, 2005 (the “September 10-Q”) to include
        the following disclosure regarding the expected effect that cash used in
        operating activities will have on future financial position, operations and
        liquidity:

      As
        a
        result of our decision to exit from the reinsurance and excess and surplus
        lines
        of businesses, we expect that we will continue to use cash from the operating
        activities of our Run-off Operations into the foreseeable future. We believe
        that the cash used to support the run-off of our business will reduce the
        liabilities that currently exist in the business, and allow us to reduce
        our
        capital commitment to the run-off business. As our capital commitment to
        the
        run-off business is reduced, we expect to be able to use such capital to
        assist
        the Company in reducing its current debt and managing its capital. We monitor
        the expected payout of the liabilities associated with the run-off business
        and
        generally adjust the duration of our invested assets to match the timing
        of
        expected payouts.

      United
        States Securities and Exchange Commission

        September
          22, 2005

        Page
          3

      We
        expect
        that the cash flows generated from the operating activities of The PMA Insurance
        Group will be positive for the foreseeable future as we anticipate premium
        and
        other service revenue collections to exceed losses and LAE and operating
        expense
        payments. We intend to be able to invest these positive cash flows and earn
        investment income.

      The
        Company will also include the following expanded disclosure regarding the
        Company’s asset/liability management process, which is currently contained in
        the “Investments” section (page 51) of the 2004 Form 10-K:

      Our
        investment strategy includes guidelines for asset quality standards, asset
        allocations among investment types and issuers, and other relevant criteria
        for
        our portfolio. In addition, invested asset cash flows consisting of current
        income and investment maturities, are structured after considering projected
        liability cash flows of loss reserve payouts that are based on actuarial
        models.
        Property and casualty claim payment demands are somewhat unpredictable in
        nature
        and require liquidity from the underlying invested assets, which are structured
        to emphasize current investment income while maintaining appropriate portfolio
        quality and diversity. The liquidity requirements are met primarily through
        operating cash flows and short-term investments.

      As
        of
        September 30, 2005, the duration of our investments that support the insurance
        reserves was x.x years*
        and the
        duration of our insurance reserves was x.x years.*

      The
        Company will explain in its disclosures the reason for any material difference
        in duration between its invested assets and estimated policy
        reserves.

      The
        Company will also prospectively expand its “Liquidity and Capital Resources”
section, to include the following disclosure regarding the impact of selling
        securities before anticipated to pay for policy liabilities:

      Investment
        grade fixed income securities, of which xx%*
        are
        publicly traded, constitute substantially all of our invested assets. The
        market
        values of these investments are subject to fluctuations in interest rates.
        Although we have structured our investment portfolio to provide an appropriate
        matching of maturities with anticipated claim payments, if we decide or are
        required in the future to sell securities in a rising interest rate environment,
        we would expect to incur losses from such sales.

      _______________________________

        *
          To be
          determined at the time of filing the Company’s periodic
          reports.

        United
          States Securities and Exchange Commission

          September
            22, 2005

          Page
            4

      Supplementally,
        the Company informs the Staff that it currently has no credit
        facilities.

      Critical
        Accounting Estimates

      Unpaid
        losses and loss adjustment expense, page 55

                2.

                We
                  believe your disclosure in Management’s Discussion and Analysis regarding
                  the reserve for loss and loss adjustment expenses could be improved
                  to
                  better explain the judgments and uncertainties surrounding this
                  estimate
                  and the potential impact on your financial statements. We believe
                  that
                  disclosures explaining the likelihood that materially different
                  amounts
                  would be reported under different conditions or using different
                  assumptions is consistent with the objective of Management’s Discussion
                  and Analysis. Accordingly, please revise MD&A to include the following
                  information for each of your lines of business within each of your
                  segments.

                ·

                Please
                  disclose the reserves accrued as of the latest balance sheet date
                  presented. The total of these amounts should agree to the amount
                  presented
                  on the balance sheet.

                ·

                Please
                  disclose the range of loss reserve estimates as determined by your
                  actuaries. Discuss the key assumptions used to arrive at management’s best
                  estimate of loss reserves within that range and what specific factors
                  led
                  management to believe this amount rather than any other amount
                  within the
                  range represented the best estimate of incurred
                  losses.

                ·

                Because
                  IBNR reserve estimates are more imprecise, please disclose the
                  amount of
                  IBNR separately from case reserves for all lines of
                  business.

                ·

                For
                  each line of your longer tail business with claims for asbestos-related
                  illnesses, environmental remediation, product liability and other
                  highly
                  uncertain exposures, please provide more precise insight into the
                  existence and effects on future operations and financial condition
                  of
                  known trends, events and uncertainties. Disclosure you should consider,
                  but not be limited to, includes the following
                  information:

                ·
                the number of claims pending at each balance
                  sheet
                  date;

                ·
                the number of claims reported for each
                  period
                  presented;

                  ·

                  the
                    number of claims dismissed, settled, or otherwise resolved for
                    each
                    period;

          United
            States Securities and Exchange Commission

            September
              22, 2005

            Page
              5

                  ·

                  the
                    nature of the claims including relevant characteristics of the
                    claimant
                    population (e.g., involves a large number of relatively small
                    individual
                    claims of a similar type);

                ·
                the total settlement amount for each
                  period;

                ·
                the cost of administering the
                  claims;

                ·
                emerging
                  trends that may result in future reserve adjustments;
                  and

                ·

                if
                  management is unable to estimate the possible loss or range of
                  loss, a
                  statement to that effect.

      RESPONSE:
        The
        Company believes that its 2004 Form 10-K currently contains significant robust
        disclosure regarding the process utilized in establishing the Company’s loss and
        LAE reserves and the uncertainties inherent in this process. Additionally,
        in
        various sections of the Company’s MD&A, the Company has directed the readers
        to these discussions by providing a cross reference to the relevant sections
        of
        the 2004 Form 10-K. For the Staff’s convenience, the Company has reproduced
        below, what it believes to be the current relevant disclosure contained in
        its
        2004 Form 10-K.

      “Business”
        Section of 2004 Form 10-K, pages 9-10

      Insurers
        establish reserves representing estimates of future amounts needed to pay
        claims
        with respect to insured events that have occurred, including events that
        have
        not been reported to the insurer. Reserves are also established for LAE
        representing the estimated expenses of settling claims, including legal and
        other fees, and general expenses of administering the claims adjustment
        process.

      After
        a
        claim is reported, claims personnel establish a “case reserve” for the estimated
        amount of the ultimate payment. The estimate reflects the informed judgment
        of
        management based on reserving practices and management’s experience and
        knowledge regarding the nature and value of the specific type of claim. Claims
        personnel review and update their estimates as additional information becomes
        available and claims proceed toward resolution. In addition, reserves are
        also
        established on an aggregate basis:

                -

                to
                  provide for losses incurred but not yet reported to the insurer;

                -

                to
                  provide for the estimated expenses of settling claims, including
                  legal and
                  other fees and general expenses of administering the claims adjustment
                  process; and

                -

                to
                  adjust for the fact that, in the aggregate, case reserves may not
                  accurately estimate the ultimate liability for reported claims.

        United
          States Securities and Exchange Commission

          September
            22, 2005

          Page
            6

      Reserves
        are estimated using various generally accepted actuarial