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SEC Comment Letter for AUSTRAL PACIFIC ENERGY LTD (CIK 0001041829) — Oct 7, 2005

AUSTRAL PACIFIC ENERGY LTD (CIK 0001041829)
Date: Oct. 7, 2005 · CIK: 0001041829 · Accession: 0000000000-05-051875

AI Filing Summary & Sentiment

File numbers found in text: 001-13803

Referenced dates: September 19, 2005, September 19, 2005, September 7, 2005

Date
September 23, 2005
Author
April Sifford
Form
UPLOAD
Company
AUSTRAL PACIFIC ENERGY LTD (CIK 0001041829)

Letter

September 23, 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 15, 2005 File No. 001-13803

Dear Mr. McGregor:

We have reviewed your response letter dated September 19, and have the following comments. We have limited our review of your filing to those issues we have addressed in our comments. Please provide a written response to our comments. 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

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

General

1. We note you have not submitted to EDGAR your response letter dated September 19, 2005. Please be advised that you are required to submit to EDGAR such correspondence. Refer to Regulation S-T for further guidance.

Quantitative and Qualitative Disclosures about Market Risk, page

2. We note your response to our prior comment 1 in our letter dated September 7, 2005. Please be advised that the requirements of Item 11 of Form 20-F apply to other financial instruments. Other financial instruments include, but are not limited to, trade accounts receivable, investments, loans, structured notes, trade accounts payable, deposits and other debt instruments. In the future, include quantitative and qualitative disclosures for any material market risk exposure (i.e., interest rate risk, foreign currency exchange rate risk, commodity price risk) you have with respect to the other financial instruments you hold. Refer to the General Instructions to Item 11(a) and 11(b) for further guidance.

Closing Comments

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. Detailed letters greatly facilitate our review. Please understand that we may have additional comments after reviewing your responses to our comments.

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

Sincerely,
April Sifford
Branch Chief

Show Raw Text
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<TEXT>
								September 23, 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 15, 2005
		File No. 001-13803

Dear Mr. McGregor:

      We have reviewed your response letter dated September 19,
2005
and have the following comments.  We have limited our review of
your
filing to those issues we have addressed in our comments.  Please
provide a written response to our comments. 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

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

General

1. We note you have not submitted to EDGAR your response letter
dated
September 19, 2005.   Please be advised that you are required to
submit to EDGAR such correspondence.  Refer to Regulation S-T for
further guidance.

Quantitative and Qualitative Disclosures about Market Risk, page
48

2. We note your response to our prior comment 1 in our letter
dated
September 7, 2005.  Please be advised that the requirements of
Item
11 of Form 20-F apply to other financial instruments.  Other
financial instruments include, but are not limited to, trade
accounts
receivable, investments, loans, structured notes, trade accounts
payable, deposits and other debt instruments.   In the future,
include quantitative and qualitative disclosures for any material
market risk exposure (i.e., interest rate risk, foreign currency
exchange rate risk, commodity price risk) you have with respect to
the other financial instruments you hold.  Refer to the General
Instructions to Item 11(a) and 11(b) for further guidance.

Closing Comments

      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.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

.	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 23, 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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