SecProbe.io

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Mail Stop 3561
							September 28, 2005

Mr. Rubens Ghilardi
Chief Executive Officer & Chief Financial Officer
Energy Company of Parana
Rua Coronel Dulcidio, 800
80420-170 Curitiba, Parana, Brazil

		RE:	Energy Company of Parana
			Form 20-F for Fiscal Year Ended December 31, 2004
			Filed June 29, 2005
			File No. 001-14668

Dear Mr. Ghilardi:

	We have reviewed your filing and have the following comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
disclosures in future filings 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 or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 20-F for Fiscal Year Ended December 31, 2004

Item 5. Operating and Financial Review and Prospects, page 50

Results of Operations for the Years Ended December 31, 2004 and
2003,
page 59

1. On page 61 you disclose that you classify expenses related to
gas
purchase contracts within financial income (expense), net, for
Brazilian GAAP purposes.  Tell us the amount of these expenses for
all periods presented and where you classify them for U.S. GAAP
purposes.  If the gas purchase contract expenses are material and
the
classification differs under U.S. GAAP, please clarify in the
notes
to the financial statements.

Results of Operations for the Years Ended December 31, 2003 and
2002,
page 62

2. Please tell us why materials and supplies expenses increased so
significantly between 2002 and 2003 and why the absolute dollar
amount of materials and supplies is so high when it appears that
the
increase is attributed principally to the Araucaria facility.  On
page 63 you refer to accrual of "a variety of related expenses."
Please explain the need for accrual of significant materials and
supplies expenses.

Liquidity and Capital Resources, page 64

3. Disclosures in the operating results and liquidity sections
should
address historical and expected trends regarding loss contingency
amounts and commitments, including commitments for which you have
suspended payment, and their reasonably likely effects on
operating
results and liquidity, if material.  You have a number of
commitments
and contingencies described in Note 20 of the financial statements
and in the Legal Proceedings section of your filing; however, your
disclosures address only your legal proceedings with Araucaria.
While it appears that the Araucaria matter is one of the most
significant exposures, there appear to be other exposures, which
either individually, or in the aggregate, could have a material
adverse effect on your liquidity or financial condition.  Refer to
SAB Topic 5Y.  Please revise in future filings.  Please show us
what
the revised disclosure would have looked like in your fiscal 2004
Form 20-F.

Contractual Obligations, page 66

4. Please revise your contractual obligations table in future
filings
to include estimated interest payments on your debt.  Because the
table is aimed at increasing transparency of cash flow, we believe
interest payments should be included in the table.  If you choose
not
to include these payments, a footnote to the table should clearly
identify the excluded item and provide any additional information
that is material to an understanding of your cash requirements.
See
Section IV.A and footnote 46 to the Commission`s MD&A Guidance
issued
December 19, 2003 available at www.sec.gov.

Item 15. Controls and Procedures, page 99

5. Please revise your future disclosures regarding your principal
executive and financial officers` conclusion as to the
effectiveness
of your disclosure controls and procedures to ensure it
encompasses
the entire definition of disclosure controls and procedures in
Exchange Act Rules 13a-15(e) and 15d-15(e).  Your current
disclosure
does not achieve this objective.  Also confirm to us that your
disclosures regarding the effectiveness of your disclosure
controls
and procedures are still accurate considering the entire
definition
of disclosure controls and procedures, or otherwise amend this
Form
20-F accordingly.

Item 18. Financial Statements

Notes to the Consolidated Financial Statements, page F-11

Note 20. Commitments and Contingencies, page F-46

a(i) Labor Contingencies, page F-46

6. If there is at least a reasonable possibility that a material
loss
in excess of the amount accrued for a contingency may occur, you
must
disclose an estimate of the amount, or range, of possible loss or
state that such an estimate cannot be made.  Refer to paragraph 10
of
SFAS 5.  We note that you provide this disclosure for certain
contingencies, but not others.  Please consider these disclosure
requirements for all material contingencies.  Please revise future
filings.  Please show us what the revised disclosure would have
looked like in your fiscal 2004 Form 20-F.

Note 28. Related-Party Transactions, page F-64

7. You disclose on page F-67 that interest income related to the
CRC
account balance was R$198,278.  Please explain where this interest
income is reflected in the table on page F-63.  The interest and
commissions income line item totals only R$166,320.

Note 32. Supplemental Information, page F-74

8. Your fiscal 2004 consolidated statement of cash flow includes a
cash outflow related to an increase in recoverable rate deficit
(CRC)
of R$ 14,873,000.  Based on review of your December 31, 2004 and
2003
consolidated balance sheets CRC assets increased by R$
161,078,000.
Please explain the difference.

Note 33. Summary of Principal Differences between Brazilian GAAP
and
US GAAP, page F-76

General

9. Your December 31, 2004 CRC receivable balance totals R$
1,197,404,000.  Note 4a(v) states that the CRC receivable balance
was
R$ 506,602 on October 1, 1997.   Please tell us your consideration
of
a valuation allowance.  In your response please specify whether
any
portion of the CRC receivable is subject to setoff against amounts
payable to the State government for dividends or other payments.
If
there is no provision for setoff, tell us how you determined that
it
was probable you would recover the uncollected balance in light of
the fact that the scheduled payments have been renegotiated and
extended several times in response to nonpayment.  You indicate
that
the first payment under the renegotiated agreement is due in
January
2005.  Please tell us whether the State government has made all
payments due during 2005 and how the recent payment history under
the
new payment schedule impacts your assessment of recovery, if at
all.
Refer to FASB Concepts Statement No. 6.  Note 22(b) states that
there
is an R$ 790,555,000 capital reserve for the CRC.  Please tell us
what this capital reserve represents.

10. Your December 31, 2004 recoverable taxes balance totals R$
80,923,000.  Note 10 states that in 2004 a significant amount of
value added taxes recoverable were disallowed resulting in a
reversal
of previously applied credits and the write-off of certain credits
not yet offset.  Considering your history of realization of the
tax
credits, amongst other factors, please tell us how the recoverable
taxes balance meets the US GAAP definition of an asset.  Please
tell
us your consideration of a valuation allowance.  Refer to FASB
Concepts Statement No. 6.

	Please respond to these comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your responses to our comments and provides any
requested
information.  Please understand that we may have additional
comments
after reviewing your responses to our comments.  Please file your
response letter on EDGAR as a correspondence file.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

       In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

		In addition, please be advised that the Division of
Enforcement has access to all information you provide to the staff
of
the Division of Corporation Finance in our review of your filing
or
in response to our comments on your filing.

	If you have any questions regarding these comments, please
direct them to Adam Phippen, Staff Accountant, at (202) 551-3336.
In
his absence, your questions may be directed to me at (202) 551-
3843.

								Sincerely,

								George F. Ohsiek, Jr.
								Branch Chief

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Mr. Rubens Ghilardi
Energy Company of Parana
September 28, 2005
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