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RESPONSE LETTER

TABLE OF CONTENTS

 Item 1. Business.
 Customers, page 10

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations.
 Liquidity and Capital Resources, page 33

 Item 7. Management’s Discussion and Analysis of Financial Condition and Results of Operations.
 Capital Requirements, page 34

 Item 8. Financial Statements and Supplementary Data
 Note 1 – Summary of Significant Accounting Policies
 Dry-Docking, page 51

 Item 8. Financial Statements and Supplementary Data
 Note 4 — Discontinued Operations, page 55

 Item 8. Financial Statements and Supplementary Data
 Note 16 – Employee Benefit Plans, page 64

 Item 8. Financial Statements and Supplementary Data
 Note 18 – Commitments and Contingencies, page 67

Table of Contents

December 21, 2005

Mr. David R. Humphrey

Branch Chief-Accountant

Securities and Exchange Commission

100 F Street N.E.

Washington, D.C. 20549

    Re:

    Crowley Maritime Corporation

    Form 10-K for the Year Ended December 31, 2004

    File 000-49717

Dear Mr. Humphrey:

     This letter sets forth the responses of Crowley Maritime Corporation (“Crowley” or “the
Company”) to the comments set forth in the Staff’s letter dated November 23, 2005 in connection
with the Form 10-K for the fiscal year ended December 31, 2004 filed by Crowley with the Securities
and Exchange Commission. For the ease of reference, we have set forth each comment in the Staff’s
letter followed by Crowley’s response.

Form 10-K for the Year Ended December 31, 2004:

Item 1. Business.

Customers, page 10

    1.

    Comment: 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.

    Response: Paragraph 39 of SFAS 131 states “An enterprise shall provide information about the
extent of its reliance on its major customers. If revenues from transactions with a single
external customer amount to 10 percent or more of an enterprise’s revenues, the enterprise
shall disclose that fact, the total amount of revenues from each such customer, and the
identity of the segment or segments reporting the revenues. The enterprise need not disclose
the identity of a major customer or the amount of revenues that each segment reports from that
customer. For purposes of this Statement, a group of entities known to a reporting enterprise
to be under common control shall be considered as a single customer, and the federal
government, a state government, a local government (for example, a county or municipality), or
a foreign government each shall be considered as a single customer.”

    The revenue from Alyeska represented 4.4% of the Company’s consolidated revenue in 2004, 2003
and 2002. Therefore, no disclosure is required pursuant to paragraph 39 of SFAS 131. If
still the case, in future filings, Crowley will clarify that the Alyeska contracts are material
to the Ship Assist and Escort Services, but not the Company as a whole. Additionally, in
future filings, if any customer exceeds 10% of the Company’s consolidated revenue, Crowley will
include the disclosures required in paragraph 39 of SFAS 131.

CROWLEY MARITIME CORPORATION

155 GRAND AVENUE • SUITE 700 • OAKLAND • CALIFORNIA • 94612 • 510.251.7500

www.crowley.com

Table of Contents

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

Liquidity and Capital Resources, page 33

    2.

    Comment: 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.

    Response: Crowley will revise the table of contractual obligations to include interest
payments in future filings.

    3.

    Comment: 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.

    Response: Crowley will revise the table of contractual obligations to remove the sublease
receipts in future filings. Crowley will retain information with respect to the sublease
receipts as a footnote to the table in order to enable the reader to more fully understand the
Company’s cash requirements.

    4.

    Comment: 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.

    Response: Crowley will supplement the table of contractual obligations with the cash
requirements related to acquisitions to which the Company is contractually committed in future
filings.

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

Capital Requirements, page 34

    5.

    Comment: 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.

    Response: Crowley will disclose its funding plans for specific arrangements to acquire or
construct vessels, such as the contract with Halter, and any other material vessel construction
contracts in future filings.

    6.

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

    Response: In the Company’s filing on Form 10-Q for the quarterly period ended September 30,
2005, filed with the Securities and Exchange Commission on November 10, 2005, the Company
disclosed the following in the first paragraph of page 32:

    On September 6, 2005, the Company completed the acquisition of Northland Fuel, a refined
petroleum products distribution business in Alaska. The purchase price was $94.5 million,
net of cash acquired. The purchase price is subject to adjustment for a period of 90 days,
as defined by the Purchase Agreement. The purchase price includes an accrual of an
additional $2.1 million of estimated additional working capital due. The purchase price
was paid by cash.

    Crowley will provide the expected source of funding for business acquisitions in future
filings.

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Item 8. Financial Statements and Supplementary Data

Note 1 – Summary of Significant Accounting Policies

Dry-Docking, page 51

    7.

    Comment: 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.

    Response: Crowley will add a critical accounting policy for dry-docking to its MD&A in future
filings, as shown below.

    Dry-docking

Under U.S. Coast Guard Rules, administered through the American Bureau of Shipping’s
alternative compliance program, all vessels must meet specified seaworthiness standards to
remain in service carrying cargo between U.S. marine terminals. Vessels must undergo regular
inspection, monitoring and maintenance, referred to as dry-docking, to maintain the required
operating certificates. These dry-dockings generally occur every two and a half years, or twice
every five years. Because dry-dockings enable the vessel to continue operating in compliance
with U.S. Coast Guard requirements, the costs of these scheduled dry-dockings for major owned
vessels are deferred and amortized on the straight-line basis until the next regularly
scheduled dry-docking period.

     The Company capitalizes dry-docking costs for major owned vessels (Tank Ships, 580’ Barges,
730’ Barges, Integrated Tug/Barge units and Articulated Tug/Barge units). Per vessel
dry-docking costs for other owned vessels (Offshore Tugs, Tractor Tugs, Near Shore Tugs,
1000-5999 DWT Barges and 6000-20000 DWT Barges) are not significant and are expensed as
incurred as repairs and maintenance expense. The types of material costs that are incurred for
dry-dockings include: regulatory and vessel classification inspection requirements, blasting
and coatings/painting, steel replacement and mobilization and demobilization to and from the
dry-docking location. During a vessel dry-docking the Company will occasionally replace vessel
machinery or equipment and perform procedures that materially enhance capabilities or extend
the useful life of a vessel. In these circumstances, the expenditures are capitalized and
depreciated over the estimated useful lives.

Item 8. Financial Statements and Supplementary Data

Note 4 — Discontinued Operations, page 55

    8.

    Comment: 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.

     Response: Paragraphs 41 and 42 of SFAS 144 state that:

    41.

    For purposes of this Statement, a component of an entity comprises operations
and cash flows that can be clearly distinguished, operationally and for financial
reporting purposes, from the rest of the entity. A component of an entity may be a
reportable segment or an operating segment (as those terms are defined in paragraph 10
of Statement 131), a reporting unit (as that term is defined in Statement 142), a
subsidiary, or an asset group (as that term is defined in paragraph 4 of SFAS 144).

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    42.

    The results of operations of a component of an entity that either has been
disposed of or is classified as held for sale shall be reported in discontinued
operations in accordance with paragraph 43 if both of the following conditions are
met: (a) the operations and cash flows of the component have been (or will be)
eliminated from the ongoing operations of the entity as a result of the disposal
transaction and (b) the entity will not have any significant continuing involvement in
the operations of the component after the disposal transaction.

    The five vessels sold in 2003 and two vessels sold during 2002 did not represent components of
the entity, as their operations were not clearly distinguished, operationally and for financial
reporting purposes, from the rest of the entity.

    The accounting for the disposal of a single vessel as discontinued operations in 2004
represented a vessel that the revenues and related costs were accounted for in separate
subsidiaries. The subsidiaries had no other operations, therefore the revenues and related
costs were clearly distinguished, operationally and for financial reporting purposes, from the
rest of the entity. Furthermore, the Company did not have any significant continuing
involvement in the operations of the vessel after the disposal transaction. Therefore, the
disposal of the vessel met the requirements of SFAS 144 to be recorded as discontinued
operations.

    9.

    Comment: 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.

    Response: The income recognized represented the reversal of accrued liabilities related to the
return of equipment to the lessor that were no longer appropriate as a result of an agreement
to sell operating equipment. It did not represent a gain on the sale of the equipment.

     The accrued liabilities represented reserves that the Company established pursuant to SFAS 5 in
accounting for the sale of our South America operations in 1999. The sale of the South America
operations were accounted for in accordance with APB 30 “Reporting the Results of Operations –
Reporting the Effects of Disposal of a Segment of a Business and Extraordinary, Unusual and
Infrequently Occurring Events and Transactions”.

    The Company made the decision in the fourth quarter of 2004 to buy the equipment out of the
leases and sell the equipment to the party subleasing the equipment. Negotiations with the
party subleasing the equipment to purchase the equipment began in September 2004. The final
agreement to sell the equipment to the party subleasing the equipment was reached in the first
quarter of 2005.

Item 8. Financial Statements and Supplementary Data

Note 16 – Employee Benefit Plans, page 64

    10.

    Comment: 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.

    Response: The defined benefit pension plans disclosed in the fifth paragraph of Note 16 are
not Company-sponsored plans, but rather are multi-employer plans sponsored by unions, of which
certain of the Company employees are members. The disclosures that Crowley followed are in
paragraph 12 of SFAS 132(R) related to multi-employer plans.

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    The Company will revise this disclosure in future filings to disclose that these defined
benefit plans are not Company-sponsored.

Item 8. Financial Statements and Supplementary Data

Note 18 – Commitments and Contingencies, page 67

    11.

    Comment: 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.

    Response: Crowley has evaluated the disclosure related to asbestos in its Form 10-K for 2004
with a view to incorporating applicable examples of potential disclosure set forth in Question
2 of Topic 5:Y so as to inform readers more fully regarding the range of reasonably possible
outcomes that could have a material effect on the Company’s financial condition, results of
operations or liquidity. The 2004 disclosure, revised to give effect to these items, is shown
below and similar information will be included in future filings.

Asbestos Litigation

    The Company is currently named as a defendant with other shipowners and numerous other
defendants with respect to approximately 16,000 maritime asbestos cases and other toxic
tort cases, most of which were filed in the Federal Courts in Cleveland, Ohio and Detroit,
Michigan. Each of these cases, filed on behalf of a seaman or his personal representative,
alleges injury or illness based upon exposure to asbestos or other toxic substances and
sets forth a claim based upon the theory of negligence under the Jones Act and on the
theory of unseaworthiness under the General Maritime Law.

    Pursuant to an order issued by the Judicial Panel on Multidistrict Litigation dated July
29, 1991, all Ohio and Michigan cases (the “Multidistrict Litigati