SecProbe.io

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								July 6, 2005

Mr. Robert J. Waters
Senior Vice President and Chief Financial Officer of EnerMark Inc.
Enerplus Resources Fund
The Dome Tower
3000, 300 - 7th Avenue S.W.
Calgary, Alberta, Canada  T2P 2Z1

	Re:	Enerplus Resources Fund
		Form 40-F for Fiscal Year Ended December 31, 2004
Filed March 14, 2005
		File No. 1-15150

Dear Mr. Waters:

      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. Please provide a written response to
our
comments.  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

Financial Statements

Note 1(k) - Accounting for Unit Based Compensation, page 76

1. Please provide to us your detailed analysis supporting your
conclusion that it is not possible for you to measure the
compensation
cost associated with your Trust Unit Rights Plan using an option
pricing model.  Please include in your analysis references to the
precise accounting literature, for Canadian and U.S. GAAP, upon
which
you relied.

Note 14 - Differences Between Canadian and U.S. GAAP, page 89

2. Please explain to us why you do not believe you are required to
provide the supplemental pro forma information described in FAS
141,
paragraphs 54 and 55, relative to your 2004 and 2003 acquisitions.

Closing Comments

      Please respond to these comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your responses to our comments and provides any
requested
information.  Detailed letters greatly facilitate our review.
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 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 Sandy Eisen at (202) 551-3864 or me at (202)
551-
3684 if you have questions regarding these comments.

								Sincerely,

								April Sifford
								Branch Chief

cc: 	Sandy Eisen
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Mr. Robert J. Waters
Enerplus Resources Fund
July 6, 2005
page 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
100 F STREET, N.E.
WASHINGTON, D.C. 20549

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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