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MILBANK,
TWEED, HADLEY & McCLOY LLP

1 Chase
Manhattan Plaza

New York,
NY 10005-1413

December 27, 2005

Mr. George
F. Ohsiek, Jr.

Branch Chief

Division of
Corporate Finance

Securities and
Exchange Commission

450 Fifth
Street, N.W.

Washington, DC
20549

  Re:

  Companhia Energética de Minas Gerais -
  CEMIG

  Form 20-F for the Fiscal Year Ended
  December 31, 2004

  Filed May 25, 2005

  File No. 1-15224

Dear Mr. Ohsiek:

On behalf of
our client, Companhia Energética de Minas Gerais — CEMIG (“CEMIG”), we submit this
response to the Staff’s additional comments received in a telephone
conversation with Staff Accountant Sarah Goldberg on December 15, 2005
(the “Additional Comments”).  The
Additional Comments peratin to comment 7 in your letter dated September 27,
2005 (the “Original Comment Letter”) regarding CEMIG’s Form 20-F for the
year ended December 31, 2004 (the “Form 20-F”).  To assist in the Staff’s review of the
responses, we precede each response with the text (in bold type) of the
Additional Comments.  For your
convenience, we have also preceded the Additional Comments with the text of
comment 7 from the Original Comment Letter and CEMIG’s response to that
comment.  CEMIG believes that it has
replied to the Additional Comments in full.
As requested, this response letter is being filed on EDGAR as
correspondence and a copy is being faxed to your attention.

Capitalized terms used in
the responses set forth below and not otherwise defined herein have the
meanings set forth in the Form 20-F.

Form 20-F
for Fiscal Year Ended December 31, 2004

Comment 7 from the Staff’s letter dated September 27,
2005

Note 4.
Deferred Regulatory Assets, page F-17

7.                                      You
disclose that certain regulatory assets have been monetarily restated based on
SELIC.  Please explain to us what you
mean by “monetarily restated.”  We assume
that you mean that the assets in question are remeasured to reflect the impact
of inflation resulting in an increase in the asset balance during periods of
rising prices and a corresponding non-cash credit to the income statement.

CEMIG’s response on November 21,
2005

We have been advised
that SELIC is one of Brazil’s benchmark interest rates.  CEMIG’s regulatory assets are restated in
value based on the SELIC rate. CEMIG confirms that the application of such
restatement results in an increase in the asset balance and a non-cash credit
to the income statement during periods of rising prices.

Additional Comments from the
Staff on December 15, 2005

(i)                                    Is
the monetary restatement of certain regulatory assets based on the SELIC rate
mandated by a regulatory authority, or is approval for such restatement
otherwise sought from a regulatory authority?

CEMIG advises
the Staff that the monetary restatement of certain regulatory assets using the
SELIC rate is mandated by ANEEL (National Electric Energy Agency), the
Brazilian electric power regulatory authority, pursuant to ANEEL Resolution No. 31,
dated January 25, 2002.

(ii)                                Is
the amount of the monetary restatement recoverable from CEMIG’s customers?

The amount of
the monetary restatement is recoverable from CEMIG’s customers pursuant to
ANEEL regulations.

(iii)                            Is the
SELIC rate determined by a regulatory authority?  If not, how is the appropriate SELIC rate
determined?

CEMIG advises
the Staff that the SELIC (Special System for Settlement and Custody) interest rate
is determined by the COPOM - Comitê de Politica Monetaria (Monetary Policy
Committee), the
primary monetary policymaking body of the Brazilian Central Bank (the “BCB”).  We understand from CEMIG that the
SELIC interest rate is the COPOM’s primary monetary policy instrument and is
calculated based on the average interest rate on overnight inter-bank loans
collateralized by government bonds that are registered with and traded on the SELIC
clearing house.  We also understand from
CEMIG that the COPOM establishes a target for the SELIC interest rate and the
BCB’s open market desk executes regular liquidity management

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operations in
the domestic money market with the goal of keeping the daily SELIC interest
rate at a targeted level.

*              *              *

Should you have any questions about the
responses in this letter, kindly contact the undersigned at (212) 530-5224 or
Steven Sandretto at (212) 530-5476.

  Very truly
  yours,

  /s/ Michael
  L. Fitzgerald

  Michael L.
  Fitzgerald

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