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Correspondence Letter

 October 4, 2006

 Mr. Larry Spirgel, Assistant Director

 United States Securities and Exchange Commission

 100 F Street, NE

 Washington, D.C. 20549

RE:
Crown Castle International Corp.

 Form 10-K for the year
ended December 31, 2005 filed on March 24, 2006

 Form 10-Q for fiscal quarters ended March 31, 2006 and June 30, 2006
filed on May 5,

 2006 and August 14, 2006, respectively.

 File No. 001-16441

 Dear Mr. Spirgel:

 We are responding to your letter dated September 22, 2006, in which you provided comment on the Crown
Castle International Corp. (“the Company”) Annual Report on Form 10-K for the year ended December 31, 2005 and Form 10-Q for fiscal quarters ended March 31, 2006 and June 30, 2006. Set forth below are the Company’s
responses to the comments raised in the comment letter. For the convenience of the Staff, each of the Staff’s comments is reproduced and is followed by the corresponding response of the Company.

 Staff Comment 1:

 Refer to your discussion of restricted stock awards in the bottom carry over paragraph of page 22 of your Form 10-Q for the quarter ended June 30, 2006 where you state that awards result in forfeiture in the event the common stock does
not achieve the performance market target. According to both SFAS 123 and SFAS 123(R), which you adopted on January 1, 2006, a market condition is not considered to be a vesting condition and an award is not deemed to be forfeited (as the term
is used in the standards) solely because a market condition is not satisfied. Please revise your disclosures to clarify your treatment of common stock awards that do not reach market performance targets.

 Company Response:

 We respectfully submit that in future filings, we will insert the following additional disclosure after the sentence that ends with “will be forfeited at the end of the vesting period (February 23, 2010)”. “Further, provided
that the requisite service is rendered, compensation cost for accounting purposes will be recognized regardless of whether or not the $37.07 market performance target is achieved.”

 Staff Comment 2:

 In
that regard, we note that non-cash compensation charges recognized for your 2003, 2004, and 2005 restricted stock grants were less than the amounts calculated at the grant dates, even though it appears that accelerated vesting levels had been fully
reached. Please advise or revise your treatment as appropriate.

 Company Response:

 We note that non-cash compensation charges disclosed for the restricted stock grants on pages 44 and 45 of the Form 10-K for fiscal year ended
December 31, 2005 are the amount of the charges recognized as a result of the accelerated vesting, and are not the aggregate charge for each award. We would like to call the Staff’s attention to the disclosures in “General
Overview-Current Year Highlights – Accelerated Vesting of Restricted Common Stock” (Page 31) and “Results of Operations – Comparison of Years Ended December 31, 2005 and 2004” (Pages 36, 38 and 39) that
discuss the total non-cash general and administrative compensation charges and the amount thereof related to the accelerated vesting. We respectfully submit that those disclosures should address the Staff’s comments.

 Staff Comment 3:

 Refer to the second paragraph of page 21, which indicates that you are exposed to fluctuations in foreign currency exchange rates and that you do not typically hedge this risk. See Item 305(a) of Regulation S-K and provide separate
quantified disclosure for your foreign currency market risk. Select from one of the three alternatives provided in Item 305(a). If the exposure is not material, see General Instruction 5B of Paragraphs 305(a) and 305(b) and demonstrate to us
how you assessed your risk.

 Company Response:

 We assess foreign currency market risk periodically. At December 31, 2005, we determined that the market risk of financial instruments associated
with changes in foreign currency rates between Australian dollars and US dollars is not material. This assessment was based on the immateriality of 1) the $61.2 million USD fair value of financial instruments subject to currency exchange risk
between the Australian dollar and the US dollar at December 31, 2005, and 2) the $6.1 million translation loss due to a hypothetical 10% unfavorable change in currency exchange rates that would be adjusted to accumulated other comprehensive
income.

 Staff Comment 4:

 Disaggregate “other income (loss)” section as required by Rules 5-03(b)7, 8, 9, and 13 of Regulation S-X. Separately state material amounts on the face of the consolidated statement of operations or the
notes, clearly indicating the nature of the transactions out of which the items arose. Items which should be separately disclosed include: interest income, interest expense, gain/loss on extinguishment of debt, dividends on preferred stock
classified as liabilities, equity in earnings of unconsolidated subsidiaries and other material items as necessary.

 Company Response:

 Non-operating income and equity in losses of unconsolidated subsidiaries were combined since they are less than 10% of net revenues. The only material
component of the non-operating expenses was the loss on repurchases of debt and liability classified preferred stock, in the amount of $119.4 million, $77.7 million and $283.8 million for the years ending December 31, 2003, 2004 and 2005,
respectively. The losses on repurchases were disclosed in footnote 7 and 10 to the consolidated financial statements. See Attachment A to this document which provides reference to the applicable disclosures on the Form 10-K. We respectfully submit
that these disclosures should address the Staff’s comments. Further, although not directly related to your comment, we also wanted to respectfully submit to you that the losses on repurchases are also discussed throughout Management’s
Discussion and Analysis of Financial Condition and Results of Operations on the Form 10-K for the year ended December 31, 2005, including on pages 31, 36, 38, 39, 42, 44 and 49.

 Staff Comment 5:

 Refer to the last paragraph on page 66 where you discuss your revenue recognition policy with regard to arrangements with multiple deliverables. We note your criteria that undelivered items must have stand-alone value to the customer in
order to be accounted for separately. Please revise your disclosure to clarify whether your policy requires that the delivered item have value to the customer on a standalone basis in order to be accounted for separately. See paragraph 9(a) of EITF
00-21.

 Company Response:

 The delivered item, the network services provided in our situation, has value on a standalone basis because it is sold separately by other vendors.

 We respectfully submit that in future filings of the Form 10-K, we will insert the following additional disclosure after the sentence that ends with
“(3) have delivery which is probable and under the control of the Company.” “In addition, the delivered item must have standalone value to the customer.”

 Staff Comment 6:

 In
that regard, based on your overview discussion on page 6, and your discussion of network services revenues on page 32, it appears that your network services revenue is primarily from project management related to the installation of customer’s
equipment and antennas on your towers and such services are “generally pursued at the request of a customer in order to facilitate (y)our leasing activities.” Tell us in detail how you considered the guidance in EITF 00-21 in evaluating
the relationship between these installation services and on-going site rental services and determining whether they represent separate units of accounting.

 Company Response:

 Disclosures surrounding network services revenues have been scaled back over the years, as network services revenues have decreased as a percentage of net revenues. However, in response to your comment, we respectfully submit that we will
modify our disclosure in future filings to describe network services revenues as follows:

 “We provide network services, such as
antenna installations, network design and site selection, site acquisition, site development and other services, on a limited basis. We have the capability and expertise to install equipment and antenna systems for our cellular, personal
communication services, enhanced specialized mobile radio, 3G, wireless data, paging and microwave customers. These activities are typically non-recurring and highly competitive, with a number of local competitors in most markets. We typically bill
for our antenna installation services on a fixed price basis.”

 See Attachment B for a discussion of our evaluation of the guidance in EITF 00-21 as it relates to the
relationship between installation services and on-going site rental services.

 Staff Comment 7:

 Refer to the bottom carryover paragraph of page 79 and tell us how much of the $48,873,000 set aside to fund reserve accounts pursuant to the Indenture
for the Asset Entities relates to potential environmental remediation costs. Explain to us your consideration of the guidance of SAB Topic 5Y and tell us why you have not included detailed disclosure of any such environmental liabilities in your
financial statements and Management’s Discussion and Analysis. In that SAB, we clearly state that we believe that environmental liabilities typically are of such significance that detailed disclosures regarding judgments and assumptions
underlying the recognition and measurement of the liabilities are necessary to prevent the financial statements from being misleading and to inform readers fully regarding the range of reasonably possible outcomes that could have a material effect
on a registrant’s financial condition, results of operations, or liquidity. Among the disclosures called for in the SAB are as follows:

•

Circumstances affecting the reliability and precision of loss estimates;

•

The extent to which unasserted claims are reflected in any accrual or may affect the magnitude of the contingency;

•

Whether, and to what extent, losses may be recoverable from third parties;

•

The contribution of other parties;

•

The period in which claims for recovery may be realized;

•

The likelihood that claims for recovery may be contested;

•

The financial condition of third parties from which recovery is expected;

•

The timing of payments of accrued and unrecognized amounts;

•

The material components of the accruals and significant assumptions underlying estimates;

•

The recurring costs of managing hazardous substances and pollutions in ongoing operations;

•

Capital expenditures to limit or monitor hazardous substances or pollutants;

•

Mandated expenditures to remediate previously contaminated sites;

•

Other infrequent or non-recurring clean-up expenditures that can be anticipated, but which are not required in the present circumstances;

•

Disaggregated disclosure that describes accrued and reasonably likely losses with respect to particular environmental sites that are individually material;

•

The consequences on amounts accrued and the range estimates for investigations and remediations that are in different stages with respect to individual sites.

 Company Response:

 The environmental remediation reserve was $2.5 million of the $48.9 million initially set aside to fund various reserve accounts pursuant to the Tower
Revenue Notes indenture dated June 8, 2005. The due diligence completed for the Tower Revenue Notes did not identify any known environmental issues that require remediation. We remediated only one site since we have owned our towers, for a cost
of less then $50,000, which is now completed. Since there are no known environmental contingencies, we respectfully submit that we have properly not made disclosure under SAB Topic 5Y.

 Staff Comment 8:

 We
note that you have filed an amendment to revise your Section 302 certifications but did not include the entire body of the report with the amendment. Please amend your Form 10-Q to provide the entire report along with your updated
certifications.

 Company Response:

 Subsequent to submission of our EDGAR filing of the Form 10-Q for the period ended June 30, 2006, we discovered that the dates set forth on the Section 302 certifications reflected a date earlier than the
date the 10-Q was submitted for filing. Since no amendment was being made to the Form 10-Q, we filed only the redated 302 certifications on the Form 10-Q/A. We believe, including after consultation with our outside counsel, that this approach is
consistent with Exchange Act Rule 12b-15; and we believe this is the common approach used by registrants to make similar amendments. We respectfully request that the Staff not require us to resubmit our Form 10-Q/A, as we believe doing so would be
confusing to our investors.

 * * * *

 We acknowledge that:

•

the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

•

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.

 If you would like to discuss any of our responses to the comments or if you would like to discuss any other matters, please
contact the undersigned at (713) 570-3083. In my absence, please contact Blake Hawk, Executive Vice President and General Counsel at (713) 570-3155.

Sincerely,

 /s/ W. Benjamin Moreland

 W. Benjamin Moreland

 Executive Vice President and Chief
Financial Officer

Cc:

Kenya Wright Gumbs

Joseph M. Kempf

 W/ attachments

 Attachment A

 The
losses on purchases of debt and liability classified preferred stock were $119.4 million, $77.7 million and $283.8 million for the years ended December 31, 2003, 2004 and 2005, respectively. Disclosure of these purchases was made in footnote 7
and 10 to the consolidated financial statements. For the convenience of the Staff, excerpts from the applicable paragraphs from our 2005 Form 10-K are as follows:

 Excerpt from page 82 of the 2005 Form 10-K;

 On June 28, 2004, the Company signed a definitive
agreement to sell CCUK to an affiliate of National Grid. On August 31, 2004, the Company completed the sale of CCUK. In accordance with the terms of the 2000 Credit Facility, the Company was required to use $1,286,568,000 of the proceeds from
the transaction to fully repay the outstanding borrowings under the 2000 Credit Facility, including accrued interest and fees of $11,183,000. The repayment of the 2000 Credit Facility resulted in a loss of $13,886,000, consisting of the write-off
of unamortized deferred financing costs. Such loss is included in interest and other income (expense) on the Company’s consolidated statement of operations and comprehensive income (loss) for 2004 (see note 3).

 Excerpt from page 85 of the
2005 Form 10-K;

 The Company’s purchases of its debt securities in 2003 and January 2004, including the redemption of the
10 5/8% Discount Notes, the purchases in public market transactions discussed above and the purchases pursuant to the cash tender offers discussed above, resulted in losses of $87,112,000 ($0.40 per share) for the year ended December 31,
2003 and $24,367,000 for the three months ended March 31, 2004.

 Such purchases were as follows:

Cash Paid

Losses on Purchases

Principal
Amount

Carrying
Value

2003

 January

 2004

2003

January
2004

(In thousands of dollars)

 10 5/8% Senior Discount Notes due 2007

$
239,160

$
239,160

$
251,867

$
—

$
18,857

$
—

 10 3/8% Senior Discount Notes due 2011

437,784

420,162

456,218

1,570

42,948

139

 9% Senior Notes due 2011

139,567

139,567

4,197

145,221

294

12,466

 11 1/4% Senior Discount Notes due 2011

192,3