SecProbe.io

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                  Paul, Weiss, Rifkind, Wharton & Garrison LLP
                           1285 Avenue of the Americas
                          New York, New York 10019-6064

Writer's Direct Dial:
(212) 373-3078

Writer's Direct Fax:
(212) 492-0078

Writer's Direct E-mail:
afoley@paulweiss.com

                                            September 23, 2005

VIA EDGAR

U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010

ATTENTION:  Jill S. Davis, Branch Chief

            Re:   Response Submitted in the Matter of EnCana Corporation's
                  2004 40-F for Fiscal Year Ended December 31, 2004
                  (File No. 1-15226)

Ladies and Gentlemen:

                  On behalf of our client, EnCana Corporation ("EnCana") and in
response to a comment letter dated September 15, 2005 (the "COMMENT LETTER")
from the staff (the "STAFF") of the Division of Corporation Finance of the U.S.
Securities and Exchange Commission (the "COMMISSION"), EnCana has asked us to
submit to you its responses to the Comment Letter (the "RESPONSES") relating to
its annual report on Form 40-F for the fiscal year ended December 31, 2004.
Attached as ANNEX A hereto, please find the Responses.

                  Please note that a letter to the Commission from EnCana
attached as ANNEX B hereto contains the required "Tandy" waiver and the other
undertakings requested in the Comment Letter.

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U.S. Securities and Exchange Commission                                        2

                  The contact information of the responsible representative at
EnCana is Mr. John D. Watson, Executive Vice-President & Chief Financial
Officer, 1800-855 2nd Street, S.W., P.O. Box 2850, Calgary, Alberta, Canada T2P
2S5.

                  In addition, please note that the submission of the Responses
is without prejudice to, and with full reservation of, all privileges, rights
and protections that may apply, including the attorney-client privilege and work
product doctrine.

                  If the Staff wishes to discuss this letter or the attached
documents, please contact Mr. Watson or me at (212) 373-3078.

                                        Very truly yours,

                                        /s/ Andrew J. Foley
                                        -----------------------------
                                        Andrew J. Foley

cc:      John D. Watson
         Gary Molnar
               EnCana Corporation

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                                                                         ANNEX A

                                Company Responses

              The headings and numbered responses set out below correspond to
the headings and numbered comments in the Comment Letter. The Company's
responses to the Staff's comments are as follows:

GENERAL

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.            Please revise your disclosure of the standardized measure to
              remove the subtotal Undiscounted pre-tax cash flows, as this
              subtotal is not contemplated by SFAS 69.

RESPONSE TO COMMENT 1

              EnCana's intent in including the subtotal referred to in your
comment as part of its standardized measure disclosure was to provide additional
information to readers. Presentation of the subtotal is consistent with the
general format of the Company's Consolidated Statement of Earnings. Although the
illustration in SFAS 69 does not include such a subtotal, SFAS 69 does not
preclude its disclosure and EnCana's intent was to provide the information as a
benefit to investors. In addition, disclosure of the subtotal does not otherwise
change the amounts required to be disclosed and in EnCana's view, its inclusion
is not misleading.

FINANCIAL STATEMENTS

CONSOLIDATED STATEMENT OF CASH FLOWS, PAGE 5

2.            We note in your reconciliation of net earnings to net cash
              provided by operating activities that you present the subtotal
              Cash flow from continuing operations above total net cash provided
              by operating activities. We note the Illustrative example in CICA
              1540, and that the subtotal presented does not include net income;
              rather the presentation only includes "items not affecting cash."
              Support your disclosure of these subtotals under Canadian GAAP as
              there does not appear to be a provision within CICA 1540 for this
              presentation.

RESPONSE TO COMMENT 2

              We note your reference to the illustrative example included in the
CICA Handbook section 1540. This is an example presented by the CICA, but is not
the sole definer of Canadian GAAP. There are no statements or principles in CICA
1540 that

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preclude the inclusion of this information to provide additional disclosure that
is meaningful to the users of the financial statements.

              The presentation format adopted in the Consolidated Statement of
Cash Flows is in accordance with Canadian GAAP. In addition, EnCana's
presentation is consistent with presentation formats used by Canadian companies
in the oil and gas industry as well as other industries, such as mining and real
estate. EnCana notes that comparability is a principle of Canadian GAAP and
considers that the inclusion of these subtotals assists in the comparison of
EnCana's Consolidated Statement of Cash Flows to other companies with which
EnCana is regularly compared.

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES, PAGE 6

A)      PRINCIPLES OF CONSOLIDATION, PAGE 6

3.            Expand your accounting policy with respect to the use of
              proportionate consolidation, to identify the legal form of each
              entity and the nature of the activities in which the entity being
              proportionately consolidated is engaged. Refer to EITF 00-1 for US
              GAAP. Also address the conditions required to avail yourselves of
              the accommodations provided in Item 17(c)(2)(vii) of Form 20-F, if
              applicable.

RESPONSE TO COMMENT 3

              EnCana has referred to EITF 00-1 and notes that, unlike EITF 00-1,
Canadian GAAP has a broad definition of joint venture activity. Accordingly, in
its Consolidated Financial Statements EnCana has set forth as its accounting
policy with respect to proportionate consolidation a statement that is
consistent with Canadian GAAP. EnCana notes that the wording in its accounting
policy is generally consistent with the wording used by Canadian issuers to
describe all joint venture activity under Canadian GAAP, including jointly
controlled assets.

              EnCana has prepared its reconciliation to U.S. GAAP in its Form
40-F in accordance with Item 17 of Form 20-F. However, in doing so, EnCana has
concluded that Item 17(c)(2)(vii) of Form 20-F is not applicable to EnCana
because there is no reconciling item.

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                                                                         ANNEX B

                                         EnCana Corporation
                                         1800-855 2nd Street, S.W.
                                         P.O. Box 2850
                                         Calgary, Alberta, Canada  T2P 2S5

                                        September 23, 2005

U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549-7010

Attention:   Jill S. Davis, Branch Chief

             Re:    Response Submitted in the Matter of EnCana Corporation's
                    2004 40-F for Fiscal Year Ended December 31, 2004
                    (File No. 1-15226)

Ladies and Gentlemen:

                  On behalf of EnCana Corporation (the "Company"), I hereby
acknowledge that:

     1.  the Company is responsible for the adequacy and accuracy of the
         disclosure in its Form 40-F for the fiscal year ended December 31, 2004
         (the "Filing");

     2.  comments by the staff ("Staff") of the Securities and Exchange
         Commission (the "Commission") or changes to disclosure in response to
         Staff comments do not foreclose the Commission from taking any action
         with respect to the Filing; and

     3.  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.

                                            Very truly yours,

                                            /s/ John D. Watson
                                            ------------------------------
                                            John D. Watson
                                            Executive Vice-President &
                                            Chief Financial Officer

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