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SEC response letter

PNM Resources                                                  Alice
A. Cobb

Alvarado
  Square                                                 Sr. Vice President, CAO

Albuquerque, NM 87158-2818

505
241-4691

Fax
505 241-2368

www.pnm.com                                                                                                                                                            [PNM
logo]

VIA EDGAR

April
13, 2005

Robert
Burnett

Staff
Accountant

United
  States
Securities and

  Exchange Commission

450
  Fifth Street, NW

Washington, D.C. 20549-0308

RE:     PNM Resources, Inc. Master Employee Savings Plan and Trust

            PNM Resources, Inc. Employee Stock Purchase Plan

            Change of independent auditors

            File No. 1-32462

Dear
Mr. Burnett:

This letter is in response to your correspondence
dated April 12, 2005 regarding your receipt of an SECPS letter from Grant
Thornton LLP, notifying the Commission that the subject plans' relationship
with Grant Thornton LLP has ceased.  Please note that the Master Employee
Savings Plan and Trust is now known as the Retirement Savings Plan.  We have
considered your comments and have included our responses herein.

We welcome your assistance to ensure our compliance
with the applicable disclosure requirements.  Representatives of PNM Resources,
Inc. ("the Company") are available to discuss these matters in more detail.
Please do not hesitate to call us at the telephone numbers listed at the end of
this letter so that we may respond to any further questions you may have.

1.            The
benefit plans noted above are required to file a Form 8-K as a result of the
client-auditor relationship ceasing.  Our records do not indicate that an 8-K
has been filed.  Since the Form 8-K was due within four days of April 7, 2005,
the date of Grant Thornton's letter, it should be filed immediately.

A Form 8-K is being concurrently filed on behalf of
the above named plans describing the nature and circumstances around the
cessation of the plans' client-auditor relationship with Grant Thornton LLP.
This filing is being made within four business days of April 7, 2005, the date
of the Grant Thornton letter referred to in the Staff's comment letter.

2.            Item
304 of Regulation S-K describes the disclosure requirements of the Item 4.01
Form 8-K.  In order for the former accountants to file the letter required by
Item 304(a)(3), a copy of the filing should be furnished to them as soon as
possible, but no later than the date you file the Form 8-K with the
Commission.  If the accountants confirming letter is not filed with the Form
8-K it should be filed with an amended Form 8-K, as Exhibit 16, within two
business days of receipt but no later than ten business days after filing the
Form 8-K.

The Company believes that the
concurrently filed Form 8-K meets the disclosure requirements of Item 304 of
Regulation S-K. The accountants were furnished a copy of the 8-K filing, and
the filing includes the accountants' confirming letter as Exhibit 16.1.

The Company acknowledges the
following:

	The Company is responsible for the adequacy and accuracy of the
disclosures 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 this action as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

The Company would appreciate
your timely response on this matter.  You may contact Tom Sategna, Corporate
Controller, at (505) 241-4615 for disclosure questions or Charles Moore,
Keleher & McLeod, at (505) 346-9110 for legal questions.

Sincerely,

/s/ Alice A. Cobb

Alice A. Cobb,

Senior Vice President, CAO

cc:   Robert Benton, SEC Division of Corporate Finance

cc:   Mike Rico, PNM Resources, Inc.

cc:   Tom Sategna, PNM Resources, Inc.