SecProbe.io

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								October 6, 2005

Mr. John D. Watson
Chief Financial Officer
EnCana Corporation
1800-855 2nd Street, S.W.
P.O. Box 2850
Calgary, Alberta, Canada  T2P 2S5

	Re:	EnCana Corporation
		Form 40-F for Fiscal Year Ended December 31, 2004
Filed February 28, 2005
      Response Letter Dated September 23, 2005
      File No. 1-15226

Dear Mr. Watson:

      We have reviewed your response letter 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.

Form 40-F for the Fiscal Year Ended December 31, 2004

Standardized Measure of Discounted Future Net Cash Flows Relating
to
Proved Oil and Gas Reserves, page 24

1. We have reviewed your response to prior comment number one and
are
unable to agree with your conclusion.  As previously noted, the
subtotal Undiscounted pre-tax cash flows is not contemplated by
SFAS
69, as noted in Illustration 5 of the statement.  Accordingly, we
reissue our prior comment in its entirety.

Note 1. Summary of Significant Accounting Policies, page 6

A) Principles of Consolidation, page 6

2. We have reviewed your response to prior comment number three.
We
note your interpretation that Canadian GAAP, unlike EITF 00-01 for
US
GAAP, has a broad definition of joint venture activity and as a
result there are certain types of entities and arrangements that
are
permitted to be proportionately consolidated under Canadian GAAP
that
would not be under US GAAP.   We also note your conclusion that
Item
17(c)(2)(vii) is not applicable to you, based on your
determination
that there is no US GAAP reconciling item. Please clarify, if
true,
that the entities that you proportionately consolidate under
Canadian
GAAP have the characteristics both in terms of the industry and
scope
of operations and the legal form and elements of shared control
contemplated by EITF 00-1.  Additionally, as previously requested
,
please expand your accounting policy to identify the legal form of
each entity and the nature of the activities in which the entity
being proportionately consolidated is engaged.  To the extent that
differences exist between Canadian and US GAAP in your use of
proportionate consolidation, please expand your reconciliation to
US
GAAP disclosure to identify this as a reconciling item or explain
that you have relied on an accommodation in Form 20-F and identify
the factors that you satisfied to avail yourself of this
accommodation.

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.

      You may contact Regina Balderas, Staff Accountant, at (202)
551-3722 if you have questions regarding comments on the financial
statements and related matters.  Please contact me at (202) 551-
3683
with any other questions.

								Sincerely,

								Jill S. Davis
								Branch Chief

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Mr. John D. Watson
EnCana Corporation
October 6, 2005
page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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