SecProbe.io

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								September 7, 2005

Mr. Bruce McGregor
Chief Financial Officer
Austral Pacific Energy Ltd.
P.O. Box 17258
Karori
Wellington, New Zealand 6033

	Re:	Austral Pacific Energy Ltd.
		Form 20-F for the Fiscal Year Ended December 31, 2004
Filed July 17, 2005
		File No. 001-13803

Dear Mr. McGregor :

      We have reviewed your Form 20-F for the Fiscal Year Ended
December 31, 2004 and have the following comment.  We have limited
our review of your filing to those issues we have addressed in our
comment.  Where indicated, we think you should revise your
document
in response to this comment.  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.

	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 filing.
We look forward to working with you in these respects.  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 number listed
at
the end of this letter.

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

Quantitative and Qualitative Disclosures about Market Risks, page
48

1. You do not include quantitative and qualitative disclosures of
market risks and indicate that you do not hold or issue relevant
types of financial instruments.  We note that your functional
currency is the US dollar, but you have operations in Australia,
New
Zealand, Canada and Papua New Guinea.  Explain to us how you
determined your functional currency to be the US dollar when it
appears that the majority of your operations are in New Zealand.
In
addition, tell us why you believe that operating in diverse
operating
environments including New Zealand, Australia, Canada and Papua
New
Guinea does not expose you to foreign currency exchange rate risk.
Refer to Item 11 of Form 20-F for further guidance.

Closing Comments

       As appropriate, please amend your filing 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

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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.

	Please contact me at (202) 551- 3684 with any questions.

								Sincerely,

								April Sifford
								Branch Chief

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Mr. McGregor
Austral Pacific Energy Ltd.
September 7, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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