SecProbe.io

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0308

         DIVISION OF
CORPORATION FINANCE

Mail Stop 03-08

September 30, 2005

Rui de Britto Alvares Affonso
Economic and Financial Officer and Investor Relations Officer
Companhia de Saneamento Basico do Estado de Sao Paulo - SABESP
Rua Costs Carvalho, 300
05429-900 Sao Paulo, SP, Brazil

	Re: 	Companhia de Saneamento Basico do Estado de Sao Paulo -
SABESP
		Form 20-F for the Fiscal Year Ended December 31, 2004
Forms 6-K for the Fiscal Quarters Ended June 30, 2005 and March
31,
2005
		File No.  1-31317

Dear Sir or Madam,

      We have reviewed the above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and do not intend to
expand our review to other portions of your documents.  Where
indicated, we think you should revise your documents in response
to
these comments in future filings.  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 information so we may better understand your disclosure.
After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

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

Item 5.  Operating and Financial Review and Prospects

1. In future filings, please include a table of contractual
obligations as required by Item 5.F of Form 20-F.  In addition to
debt-service obligations, make sure your disclosure includes other
contractual obligations such as lease commitments, purchase
obligations, and other long-term liabilities reflected on your
balance sheet as of the latest fiscal year end.

2. Tell us, and disclose in future filings in a separately
captioned
section, your off-balance sheet arrangements that have or are
reasonably likely to have a current or future effect on your
financial condition that are material to potential investors.  If
you
do not have any off-balance sheet arrangements, disclose that fact
as
well.  See Item 5.E of Form 20-F.

Item 18.  Financial Statements

Note 3.  Significant Accounting Principles, F-11

(h) Property, plant and equipment, F-13

3. We note that you received contributions of property, plant, and
equipment from third parties and from government entities. Tell us
how you determine and record the basis of the equipment
contributed
from the third parties and government entities as well as the
difference, if any, from US GAAP.

Note 8.  Property, Plant and Equipment, F-25

4. We note that you include concession assets in property, plant
and
equipment on the balance sheet for BR CL and US GAAP.  It appears
these assets meet the definition of intangible assets in FAS 142
under US GAAP and should be presented separately on the balance
sheet.  In future filings, please reflect this presentation on the
US
GAAP balance sheet and make sure your disclosure includes all of
the
requirements of paragraphs 42-45 of FAS 142, or advise us
otherwise.

Note 14.  Provisions for Contingencies, F-46

5. We note that you have several lawsuits against the Company that
you assessed the likelihood as possible and therefore, accrued no
provision.  For each material lawsuit in which one or both of the
conditions in paragraph 8 of FAS 5 are not met, please tell us and
disclose in future filings the nature of the individual
contingency,
and estimate of the possible loss or range of loss or state that
such
an estimate cannot be made See paragraph 10 of FAS 5.

Note 23.  Summary of Differences Between BR CL and US GAAP, F-60

General

6. In future filings, please include a discussion regarding the
impact of recently issued accounting standards on your financial
statements.  See SAB Topic 11:M.  If, by the nature of the
pronouncement, it is clear that it will have no impact on you, no
further discussion is needed.  However, unless it is clear from
your
financial statements that a standard will not apply to you, then
you
should affirmatively indicate the anticipated effect of adoption.
To
the extent the pronouncement will have a material effect on your
financial statements; such disclosure should be considered in the
financial statements as set forth in the SAB.

(l) Provision for dividends and interest on shareholders` equity,
F-
70

7. We note that you accrue dividends for BR CL and US GAAP
purposes
that have not been ratified by the shareholders.  Please tell how
this is appropriate under US GAAP and the GAAP pronouncements you
relied upon to form your conclusion.

(o) Discounting, F-71

8. We note that there are differences between BR CL and US GAAP
concerning discounting of trade receivables and payables and  you
state you did not include a reconciling item from BR CL to US
GAAP.
Please tell us why you did not include a reconciling item, and the
US
GAAP pronouncements you relied upon to form your conclusion.
Please
clarify your disclosure in future filings.

Note 26.  Segment Information, F-87

9. In future filings, please disclose for the periods presented
total
assets, interest revenue and interest expense for each reportable
segment as required by paragraph 27 of FAS 131.

*	*	*	*

      Please send us your response to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter keying your responses to our
comments
and provide any requested supplemental information.  Please file
your
response letter on EDGAR.  Please understand that we may have
additional comments after reviewing your responses to our
comments.

	 We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 Dave Irving, Staff Accountant, at (202) 551-
3321, or, in his absence, to Donna Di Silvio, at (202) 551-3202 if
you have questions regarding comments on the financial statements
and
related matters.  Please contact me at (202) 551-3841 with any
other
questions.

Sincerely,

Michael Moran
Branch Chief
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Rui de Britto Alvares Affonso
Companhia de Saneamento Basico do Estado de Sao Paulo - SABESP
September 30, 2005
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