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  Michael Fay

  Patrick Kuhn

  Joe Foti

  Division of Corporate
  Finance

  Securities and Exchange
  Commission

  450 Fifth Street, N.W.

  Washington, D.C.  20549

  Re:

  Standard Parking Corporation

  File No. 000-50796

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

Dear
Mr. Fay:

On
behalf of Standard Parking Corporation, a Delaware corporation (the “Company”),
and in connection with your review of the above referenced filing, we are
writing in response to the Staff’s additional comment in your letter dated
April 28th.

   To facilitate your review, we have provided
supplemental information in our response to your comment.  For convenience, we have reprinted the Staff’s
comment below in bold, with the corresponding response set forth immediately
below the applicable comment.

SEC comment

Principles of Consolidation, page
46

1.                                      Refer to prior
comment 5. Your response is too general to support that the 5 single purpose
entities subject to consolidation under FIN 46(R).  Please provide in more detail your evaluation
of the 5 single purpose entities as potential variable entities under FIN
46(R).  In your response, please address
the scope exceptions under paragraph 4(h) of FIN 46(R).

Company response

The entities are joint ventures formed by the
Company and an unrelated party to provide parking management and related
services to various enterprises such as property owners and/or government
organizations.  The entities have no
assets or liabilities.  The entities
provide services to specific properties on a contractual basis.  The services will typically include revenue
collection and controls and payment of expenses on behalf of the property
owners and/government organizations.

The entities will distribute any excess funds
remaining to the property owner on a monthly basis.  In addition, the entities provide financial
statements for the property owners and/or governmental organizations. The
entities receive a fee from the property owners or governmental organizations for
providing parking and parking related management services as described.

These 5 entities are not consolidated into
the Company’s financial statements because the Company is not the primary
beneficiary.  In addition, the Company is
not the reporting enterprise as defined in FIN 46(R).

The evaluation of each entity addressing the
scope exceptions under paragraph 4(h) of FIN 46(R) is as follows:

(1)                                  The property owners
or governmental organizations did not participate in the design of the
entities.

(2)                                  The entities
only provide parking related services for the property owners or governmental
organizations.

(3)                                  The property owners
or governmental organizations provide no equity, debt or financial support to
the entities.

(4)                                  The activities
of the entities are not related to any securitizations or asset-backed
financing of the property owners or governmental organizations.

Accordingly, none of the conditions included
in Paragraph 4(h) are considered applicable.

  Entity #1

  Commencement of Operations

  Nature of Activities

  % Ownership

  Location

  A-M Frontier Field

  June 1996

  Management of Parking Lot

  50.0%

  Rochester NY

The property is owned by “The Greater
Rochester Outdoor Sports Facility Corporation”, a party not related to the
entity or the Company

  Entity #2

  Commencement of Operations

  Nature of Activities

  % Ownership

  Location

  Orlando International
  Airport Shuttle

  October 1992

  Management of Shuttle
  Operations

  38.25%

  Orlando FL.

The property is owned by “The Greater Orlando
Aviation Authority, a public and governmental body, a party not related to the
entity or the Company

  Entity #3

  Commencement of Operations

  Nature of Activities

  % Ownership

  Location

  French Market Lot

  May 2003

  Management of Parking Lot

  50.0%

  New Orleans LA.

The property is owned by “The French Market
Corporation”, a party not related to the entity or the Company.

  Entity #4

  Commencement of Operations

  Nature of Activities

  % Ownership

  Location

  City of New Orleans
  Parking Meters

  April 2004

  Management  of Parking Meters

  50.0%

  New Orleans LA.

The parking meters are owned by “The City of
New Orleans”, a governmental body and a party not related to the entity or the
Company.

  Entity #5

  Commencement of Operations

  Nature of Activities

  % Ownership

  Location

  A-M Rochester Airport

  January 1992

  Management  of Parking Lot

  50.0%

  Rochester N.Y..

The parking lots are owned by “Monroe County
Airport Authority” on behalf of The Greater Rochester International Airport, a
governmental organization and a party not related to the entity or the Company.

We will expand our disclosure in future
filings to include the fact that we are not the primary beneficiary for these
entities.

The Company hereby
acknowledges that:

                (i)            we are responsible for the adequacy and accuracy of the
disclosure in our filings;

                (ii)           staff comments or changes to disclosure in response to
staff comments in our filing reviewed by the staff do not foreclose the
Commission from taking any action with respect to our filing; and

                (iii)          we 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.

  STANDARD
  PARKING CORPORTION

  Dated:
  May 12, 2005

  By:

  /s/
  G. MARC BAUMANN

  Executive
  Vice President, Chief Financial Officer, and Treasurer (Principal Financial
  Officer)

  Dated:
  May 12, 2005

  By:

  /s/
  DANIEL R MEYER

  Senior
  Vice President, Corporate Controller and

  Asst. Treasurer (Principal
  Accounting Officer)