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CORRESP
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      Correspondance

    Robert
      J. Waters

    Sr.
      Vice President & Chief Financial Officer

    Enerplus
      Resources Fund

    The
      Dome Tower

    3000,
      333-7th
      Avenue SW

    Calgary,
      Alberta T2P 2Z1

    Tel
      403.298.1295

    Fax
      403.298.2299

    www.enerplus.com

    July
      27, 2005

    Ms.
      April Sifford

    United
      States Securities and Exchange Commission

    100
      F Street N.E.

    Washington
      D.C. 20549

    Dear
      Ms. Sifford:

    Re:
      Enerplus Resources Fund Form 40-F for fiscal year ended December 31,
      2004

    This
      letter is in response to your letter dated July 6, 2005 regarding your review
      and comments on the December 31, 2004 Form 40-F of Enerplus Resources Fund
      (“Enerplus”).

    In
      connection with our response, Enerplus acknowledges:

              •

              it
                is responsible for the adequacy and accuracy of the disclosure in
                it’s
                December 31, 2004 Form 40-F filing;

              •

              United
                States Securities and Exchange Commission (“SEC”) staff comments or
                changes to disclosure in response to SEC staff comments do not foreclose
                the SEC from taking any action with respect to the filing;
                and

              •

              it
                may not assert SEC staff comments as a defense in any proceeding
                initiated
                by the SEC or any person under the federal securities laws of the
                United
                States.

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

    SEC
      Comment:

    “Please
      provide to us your detailed analysis supporting your conclusions that is it
      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 with you relied.”

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    Enerplus
      Response:

    A.
      Canadian GAAP Application

    Section
      3870 of the Canadian Institute of Chartered Accountants Handbook (the
“Handbook”) requires stock-based compensation plans to be accounted for at the
      fair value of the equity instruments exchanged for employee services. Generally,
      compensation cost is determined based on the fair value of the equity instrument
      at the date of grant. Paragraph 33 of Handbook Section 3870 states:

    “The
      fair value of a stock option (or its equivalent) is estimated using an option
      pricing model (for example, the Black-Scholes or a binomial model) that takes
      into account as of the grant date:

              (a)

              the
                exercise price

              (b)

              the
                expected life of the option

              (c)

              the
                current price of the underlying
                stock

              (d)

              its
                expected volatility

              (e)

              expected
                dividends on the stock (except as provided in paragraphs 3870.51
                and
                3870.52); and

              (f)

              the
                risk-free interest rate for the expected term of the option. For
                options
                that an enterprise grants on its own stock, the risk-free interest
                rate
                used is the rate currently available on zero coupon Canada government
                bonds with a remaining term equal to the expected life of the
                options.

    Upon
      review of Section 3870, Enerplus determined it was unable to calculate the
      fair
      value of the trust unit rights using an option-pricing model for two reasons.
      First, Enerplus was and remains unable to calculate the exercise price as
      indicated under (a) in Paragraph 33. Second, Enerplus was and remains unable
      to
      reasonably estimate expected dividends (cash distributions for a trust) as
      indicated under (e) in Paragraph 33.

    Exercise
      Price

    Under
      the terms of our trust unit rights incentive plan, there is a reduction in
      the
      trust unit rights exercise price should cash distributions exceed 2.5% of net
      property, plant and equipment (PP&E) on a quarterly basis. The quantum of
      the deduction is not constant, rather it varies depending on cash distributions
      and the return generated over and above the specified percentage of net
      PP&E. Net PP&E also varies depending on the timing and amount of capital
      expenditures, acquisitions and dispositions, depletion, depreciation and
      amortization, and if applicable, ceiling test writedowns.

    Between
      2002 and 2004 the quarterly reduction to trust unit rights exercise prices
      has
      ranged from 0% to 38% of the cash distributions paid in that quarter, or between
      $0.00 and $0.40 per trust unit. This again highlights the fact that reductions
      to exercise price are uncertain and cannot be reasonably estimated at the date
      of grant.

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    The
      guidance in Paragraph 52 of Handbook Section 3870 regarding dividend equivalents
      (i.e. cash distributions) that can be applied to reduce the exercise price
      is
      not appropriate for our trust unit rights incentive plan. Paragraph 52 states:

    “the
      fair value of an award of stock units on which dividend equivalents are paid
      to
      employees or are applied to reduce the exercise price pursuant to anti-dilution
      provisions is estimated based on a dividend payment of zero”

    The
      assumption of a zero dividend yield should only be applied when the dividend
      or
      dividend equivalents applied to the exercise price put
      the unit right holder in an economically equivalent position to an actual
      unitholder.
      Reductions to exercise price, if any, are not economically equivalent to cash
      distributions paid as only the excess distributed over the hurdle rate reduces
      the exercise price. This illustrates that the unit right holder is not in the
      same economic position of a unitholder who actually received the cash
      distribution. Therefore, the assumption of the zero dividend yield is not
      appropriate for our trust unit rights incentive plan.

    With
      respect to the calculation of the reduction, the two key components of the
      calculation are cash distributions and net PP&E. Enerplus is unable to
      estimate both of these amounts at the date of grant for future periods and
      therefore is unable to calculate future reductions to the exercise price of
      the
      trust unit rights.

    Cash
      Distributions

    For
      a traditional corporation, the “dividend” is a relatively minor input variable
      in an option pricing model, as it typically represents only 1-2% of the
      corporation’s cash flow. However, for Enerplus, our cash distributions represent
      a more significant number. Enerplus has typically distributed to its unitholders
      a majority (70-100%) of the cash flow generated by the underlying business.

    Prior
      to 2004, our monthly cash distribution varied from month-to-month as the
      underlying cash flow from operations varied. During this period, our pay-out
      ratio typically exceeded 90% of cash flow. Since the end of 2003, Enerplus
      has
      held distributions relatively constant and our payout ratio has declined to
      a
      current level of 71%. This strategy has been in response to the current business
      environment including:

              •

              unusually
                high commodity prices;

              •

              increasing
                development capital spending;

              •

              a
                desire to use cash flow to fund a greater portion of capital spending
                (instead of bank debt);

              •

              a
                desire to preserve our balance sheet and credit capacity; and

              •

              a
                shift in capital market sentiment towards a “self-sustaining” model for
                income funds.

    The
      fact that our distribution payments have been relatively constant at $0.35
      per
      unit over the recent period is no indication that they will remain at this
      level, just as we have no assurance that the current business environment will
      be sustained. In fact, we recently

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    announced
      an increase to $0.37 per unit effective for the August 2005 distribution. You
      will note in our MD&A and investor relations material, we specifically do
      not predict future distributions or provide assurance over continued
      distributions. We also clearly indicate that distributions will vary with the
      underlying cash flow of the business, and our banks and bondholders have the
      ability to force the suspension of distributions in the event we breach our
      credit covenants.

    The
      amount of cash available for Enerplus to pay distributions depends on the level
      of net cash flow received from operating subsidiaries pursuant to royalty
      agreements, loan agreements, dividend, and distribution payments. Management
      constantly evaluates and assesses net cash flow and determines the distribution
      payment on a monthly basis.

    Net
      cash flow available for distribution can vary significantly from period to
      period and is dependent upon a number of factors which may cause us to change
      the distribution, such as:

              •

              realized
                commodity prices (a small change in commodity prices can have a
                significant impact on cash flows);

              •

              production
                levels;

              •

              hedging
                gains and losses;

              •

              acquisition
                or disposition activity;

              •

              taxability
                of the operating company
                subsidiaries;

              •

              debt
                levels and credit capacity;

              •

              foreign
                exchange;

              •

              capital
                spending; and

              •

              operating
                and administrative costs.

    These
      variables are not known and cannot be reasonably estimated at the date of grant
      as they are contingent upon the occurrence of future events. Since our
      distributions are directly driven by the amount of cash flow available for
      distribution, it is important to appreciate the volatility in our business.
      As a
      result of this volatility, during the past five years annual cash available
      for
      distribution per unit has varied from $3.32 to $5.67. The graphs attached in
      Appendix I illustrate the volatility of some these variables.

    Net
      Property, Plant and Equipment

    Net
      PP&E is another variable in calculating the hurdle rate of 2.5% return on
      capital. Net PP&E can vary significantly from period to period. For example,
      during the last five years the annual increase in net PP&E has ranged
      between $120 million (5%) and $930 million (167%). As previously noted, the
      fluctuations in net PP&E are due to a number of reasons, including capital
      expenditures, acquisitions and dispositions, depletion, depreciation and
      amortization, and if applicable, ceiling test writedowns. Our ability to make
      property and corporate acquisitions is dependent upon the availability of assets
      which meet our acquisition criteria, the competition for those assets and our
      ability to access equity markets or raise sufficient debt to finance the
      acquisitions. Often, our decision with respect to equity financings versus
      debt
      financings is dependent upon the market price of our trust units, which can
      fluctuate significantly over time as illustrated by Enerplus’ historical trading
      chart in Appendix II. The graphs attached in Appendix III demonstrate the
      volatility of these

        4

    variables,
      which are contingent upon the occurrence of future events that cannot be
      reasonably estimated at the date of grant.

    In
      addition to the variables above, commodity prices impact net PP&E values as
      they directly impact acquisition, disposition and development economics.
      Furthermore, commodity prices impact the depletion calculation as stated
      reserves change with fluctuations in commodity prices, due to the associated
      economic impact of the price change on producing the reserves.

    Employee
      Choice with Respect to Declining Strike Price

    Another
      feature in Enerplus’ plan that makes it extremely difficult to apply an options
      pricing model is the fact that our employees have a choice as to whether they
      will use the declining strike price or elect to use the original fixed strike
      price when exercising their rights. This alternative has been available to
      officers since inception, but only available to employees since June
      2003.

    In
      certain circumstances, it may be more advantageous to use the original fixed
      strike price because it permits a Section 110 (1) (d) deduction under the Income
      Tax Act (Canada), effectively lowering the employee’s tax rate on the
      transaction. Enerplus has a model available to employees on its internal web
      site that assists in making this decision. The data required to make this
      decision includes, among other things, knowledge of Enerplus’ trust unit market
      price at the time of exercise, the employee’s personal tax rate, the
      availability of capital loss carry forwards and the number of vested rights
      being exercised by the employee.

    We
      cannot predict the number of employees and the corresponding number of units
      that will be exercised at either strike price alternative, since we would need
      to forecast the trust unit market price at the time of exercise. Again, this
      decision is contingent upon future events that cannot be reasonably estimated.
      We refer to Paragraph 36 of Handbook Section 3870:

    “It
      may be extremely difficult, if not impossible, to estimate the fair value of
      a
      stock option reasonably when its exercise price decreases (or increases) for
      a
      specified amount with specified changes in the price of the underlying stock”.

    The
      choice between the strike price alternatives is extremely sensitive to the
      price
      of the underlying stock at the time of exercise and therefore we believe
      Paragraphs 36 and 37 of the Handbook apply.

    Use
      of the Intrinsic Method

    Paragraph
      36 of Handbook Section 3870 contemplates and addresses situations where fair
      value cannot be reasonably estimated at the date of grant. Paragraph 36 states:

              “It
                is usually possible to estimate the fair value of most stock options
                and
                other equity instruments reasonably at the date they are granted.
                However,
                in unusual circumstances, when the terms of a stock option or other
                equity
                instrument make it virtually impossible to estimate the instrument's
                fair
                value reasonably at the date it is

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    granted,