SecProbe.io

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Mail Stop 3-8

								March 21, 2005

By Facsimile and U.S. Mail

John Loyack
Chief Financial Officer, Sr. VP
PNM Resources Inc.
Alvarado Square
Albuquerque, NM 87158

		RE:	PNM Resources Inc.
			File No. 333-32170
			Form 10-K for the year ended December 31, 2004

Dear Mr. Loyack:

	We have reviewed your filing and have the following comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
disclosures in future filings 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 supplemental information so we may better
understand your disclosure.  After reviewing this information, we
may
or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

*************

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004

General

1. Where a comment below requests additional disclosures or other
revisions to be made, these revisions should be included in your
future filings, as applicable.

Utility Operations, page 3

2. Please tell us whether you have any excise or similar type
taxes.
Please indicate whether you consider payments for franchise
agreements similar to an excise tax including how such taxes are
levied on the customer.  To the extent you have excise or excise
type
taxes you should disclose in a footnote whether you are presenting
your collections and payments of these fees on a gross or net
basis.
If they are presented on a gross basis, also disclose the amounts
of
fees included in each revenue and expense caption.  See Rule 5-
03.1
of Regulation S-X.

Note 13. Asset Retirement Obligations, page F-75

3. We note your disclosure that upon implementation of SFAS 143
the
net difference between the amounts determined to represent legal
AROs
under SFAS 143 and the Company`s previous method of accounting for
decommissioning costs were recognized as a cumulative income
effect
of a change in accounting principle.  In this regard, we note that
you had dis-applied SFAS 71 on December 31, 1999, and pursuant to
the
Global Electric Agreement, reapplied FAS 71 in the first quarter
of
2003.  We further note that two of your nuclear generating units
currently are included in rate base, and one is excluded.  In this
regard, explain to us the historical rate recovery of
decommissioning
costs of these three specific nuclear units.  If decommissioning
costs were previously collected in rates on unit three, please
explain if the regulator has approved the company`s retention of
such
amounts or whether you would have to refund decommissioning costs
if
not utilized.  We assume no cumulative income effect was recorded
on
units in rate base.  If otherwise, please explain.  In short,
please
explain your basis for recording a cumulative effect upon adoption
of
SFAS 143 as opposed to a regulatory liability.   If you obtained
the
opinion of regulatory council as to the potential regulatory
treatment, please summarize the opinion. We may have further
comment.

Note 10. Pension and Other Postretirement Benefits, page F-64

4. Please explain to us how you calculate the market related value
of
plan assets as that term is defined in SFAS 87.   Since there are
alternative ways to calculate the market value of plan assets and
it
has a direct impact on your pension expense, we believe you should
disclose how you determine this amount in future filings.

Note 14. Commitments and Contingencies, page F-76

5. We note your disclosure regarding your twenty year operating
lease
arrangement for the output of a gas-fired generating plant. You
further disclosed that the natural gas used to generate the output
is
procured on the open market by Wholesale.  In this regard, please
describe your procurement arrangement for providing natural gas to
this entity.  Tell us whether your operating lease payments under
this arrangement are fixed and whether you consider this a
variable
interest in the entity.  Please be detailed in your analysis.
Furthermore, if you are assuming fuel risk associated with your
gas
procurement arrangement then please provide to us your FIN 46R
analysis with respect to this variable interest.  Finally given
the
length of the lease and output requirements, show us how it
doesn`t
meet the requirements of a capital lease under paragraph 7 of SFAS
No. 13. We may have further comment.

	As appropriate, respond to these comments within 10 business
days or tell us when you will provide us with a response.  Please
provide us with a response letter that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your response letter as a correspondence file on EDGAR.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed 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.

	If you have any questions regarding these comments, please
direct them to Robert Babula, Staff Accountant, at (202) 824-5562
or,
in his absence, to the undersigned at (202) 942-1885.  Any other
questions regarding disclosures issues may be directed to H.
Christopher Owings, Assistant Director at (202) 942-1900.

							Sincerely,

							Jim Allegretto
							Senior Assistant Chief
Accountant

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March 22, 2005
Page 4

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