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								November 23, 2005
Zip+4 Code:  20549-0305

Via Fax & U.S. Mail
Crowley Maritime Corporation
John Calvin, Senior Vice President and Controller
155 Grand Avenue
Oakland, California 94612

		Re:	Crowley Maritime Corporation
			Form 10-K for the Year Ended December 31, 2004
       			File 000-49717

Dear Mr. Calvin:

Based upon an examination restricted solely to considerations of
the
Financial Statements, Management`s Discussion and Analysis, and
Selected Financial Data, the staff has the following comments on
the
above-referenced documents.  Where indicated, we think you should
revise your 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 Fiscal Year Ended December 31, 2004

Item 1- Business

Customers, page 10

1. You state that a material amount of revenues are derived from
contracts with Alyeska.  As such, if applicable, please revise
future
filings to include the disclosure required in paragraph 39 of SFAS
131.

Item 7- Management Discussion and Analysis of Financial Condition
and
Results of Operations.

Liquidity and Capital Resources, page 33

2. When presenting contractual obligations, please ensure that all
obligations are shown in the table, including interest payments on
your indebtedness.  See FR-72 for guidance.

3. We believe your table of contractual obligations should reflect
the
gross amount of your operating lease obligation, supplemented with
additional information that is material to an understanding of
your
cash requirements.  This additional information could include the
amount of expected sublease receipts as well as a discussion of
any
existing escalation clauses or the terms of renewal or purchase
options.

4. The table of contractual obligations should be supplemented
with
information regarding cash requirements related to acquisitions,
such
as your agreement to purchase a petroleum products distribution
business from Northland and YFC.

Capital Requirements, page 34

5. We note your disclosure on pages 33-34 regarding your general
belief that funds needed for the acquisition and construction of
vessels will continue to be available.  However, when you disclose
a
specific arrangement to construct vessels, such as your contract
with
Halter, please include disclosure of your specific funding plans
for
that arrangement.

6. Similarly, please state the expected source of funding for your
acquisition of a petroleum products distribution business from
Northland and YFC.

Item 8- Financial Statements and Supplementary Data

Note 1- Summary of Significant Accounting Policies

Dry-Docking, page 51

7. Due to the significance of costs associated with dry-docking
and
the nature of costs capitalized,  please tell us and revise future
filings to disclose the nature and types of costs you capitalize
during dry-docking within the critical accounting policies section
of
MD&A.

Note 4- Discontinued Operations, page 55

8. We note your disclosure of gain on asset sales in Note 10 to
your
financial statements.  Also, on the top of page 33, you discuss
the
sale of five vessels in 2003 and two vessels during 2002.  In this
regard, and in light of your accounting for the disposal of a
single
vessel as discontinued operations in 2004, please explain why
these
previous vessel sales were not accounted for as discontinued
operations under SFAS 144.

9. You state that you recorded income of $4,021,000 as a result of
reaching an agreement, in principal, to sell operating equipment
in
2005 to the party currently subleasing the operating equipment.
In
this regard, please tell us your basis in accounting literature
for
recognizing income prior to finalizing the sale of this equipment.

Note 16- Employee Benefit Plans, page 64

10. In the fifth paragraph of Note 16, you indicate that you make
contributions to certain defined benefit pension plans.  However,
it
appears you have not included any disclosure pursuant to
paragraphs 5-
8 of SFAS 132(R) with respect to the plan assets and obligations
of
these defined benefit pension plans.  Please explain
supplementally.

Note 18- Commitments and Contingencies

Asbestos Litigation, page 67

11. In accordance with SAB Topic 5:Y, please expand your
disclosure
relating to asbestos litigation and environmental proceedings to
include the range of reasonably possible outcomes that could have
a
material effect on your financial condition, results of
operations, or
liquidity.  Also disclose a reasonably possible range of loss in
quantified terms.  In addition, please clarify the period in which
claims for recovery may be realized and the likelihood that such
claims for recovery may be contested.

      As appropriate, 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 that keys your responses to
our
comments and provides any requested supplemental 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.

      Pursuant to Rule 101(a)(3) of Regulation S-T, your response
should be also be submitted in electronic form, under the label
"corresp" with a copy to the staff.

	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.

      You may contact Juan Migone at (202) 551-3312 or undersigned
at
(202) 551-3211 if you have questions regarding comments on the
financial statements and related matters.

      Sincerely,

      David R. Humphrey
      Branch Chief-Accountant

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John C. Calvin, Vice President and Controller
Crowley Maritime Corporation
November 23, 2005
Page 4

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