SecProbe.io

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								December 1, 2005

Mr. Wang Guoliang
Chief Financial Officer
PetroChina Company Limited
16 Andelu
Dongcheng District, Beijing, 100011
The People`s Republic of China

	Re:	PetroChina Company Limited
		Form 40-F for Fiscal Year Ended December 31, 2004
Filed June 29, 2005
      File No. 001-15006

Dear Mr. Guoliang:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  Where indicated, we think you should
revise your document 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 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 numbers listed
at
the end of this letter.

Form 40-F for the Fiscal Year Ended December 31, 2004

Controls and Procedures, page 121

1. We note that your principal officer has concluded that your
disclosure controls and procedures were effective as of the end of
the period covered by your annual report "except as disclosed in
the
following paragraphs."  Please note that your certifying officer
must
definitively conclude that your disclosure controls and procedures
are either effective or ineffective.  Please reconsider your
disclosure and the evaluation made by your principal officer as of
the end of the period covered by your Form 20-F and amend your
filing
to conclusively state the results of the principal officer`s
evaluation of the Company`s disclosure controls and procedures as
of
December 31, 2004.

2. Item 15(d) of Form 20-F requires that you disclose any change
in
your "internal control over financial reporting" identified in
connection with the evaluation required by paragraph (d) of 17 CFR
240.13a-15 or 240.15d-15 that occurred during the period covered
by
the annual report that has materially affected, or is reasonably
likely to materially affect, your internal control over financial
reporting.  Given the commencement of a plan for remedial measures
you have identified, please clarify whether or not this resulted
in
any changes to internal control over financial reporting during
the
period covered by the report.  If changes were made but they were
not
during the period covered by the report, please indicate when the
changes were made.

Note 3. Summary of Principal Accounting Policies, page F-9

(g) Oil and gas properties, page F-11

3. We note your statement that "The Group did not incur and does
not
anticipate to incur any material dismantlement, restoration or
abandonment cost given the nature of its onshore producing
activities
and current PRC regulations governing such activities."  Please
confirm, if true, that you are not legally obligated for the
retirement of your tangible long-lived assets that resulted from
the
acquisition, construction, development and/or normal operation of
those assets and therefore, are not required to recognize any
liabilities in accordance with the guidance set forth in SFAS 143
for
purposes of the US GAAP reconciliation.  Please also tell us
whether
or not you have historically incurred costs to retire your assets,
such as, but not limited to plugging of wells, and removal of
equipment.  In addition, please tell us whether or not your
adoption
of FIN 47 will affect your current interpretation of SFAS 143 for
US
GAAP.

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.

	 You may contact Jennifer Goeken at (202) 551-3721 if you
have
questions regarding comments on the financial statements and
related
matters.  Please contact me at (202) 551-3683 with any other
questions.

								Sincerely,

								Jill S. Davis
								Branch Chief

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Mr. Wang Guoliang
PetroChina Company Limited
December 1, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F Street, NE
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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