SecProbe.io

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									November 17, 2005

Mail Stop 3561

Via US Mail and Facsimile

Mr. John J. Nicola
Chief Financial Officer
3245 Richmond Terrace
Staten Island, New York 10303

Re:	K-Sea Transportation Partners LP
	Form 10-K for the year ended June 30, 2005
	Form 10-Q for the quarter ended September 30, 2005
	Commission file #: 001-31920

Dear Mr. Nicola:

We have reviewed your November 10, 2005 response letter and have
the
following comments.  Where expanded or revised disclosure is
requested, you may comply with these comments in future filings.
If
you disagree, we will consider your explanation as to why our
comments are inapplicable or a revision is unnecessary.  We also
ask
you to provide us with supplemental information so we may better
understand your disclosure.  Please be as detailed as necessary in
your explanation.  We look forward to working with you in these
respects and welcome any questions you may have about any aspects
of
our review.

* * * * * * * * * * * * * * * * * * * * * * *
Form 10-K for the year ended June 30, 2005

Management`s Discussion and Analysis

1. We note from your response to comment 1 that you are requesting
that we allow you to maintain your current presentation format of
net
voyage revenue in your MD&A section.  Although we may not have
objected to your presentation of this non-GAAP measure in the
past,
the Staff has become more stringent on the guidelines that
registrants must follow in presenting a non-GAAP measure such as
net
voyage revenue.  We will not object to a discussion of net voyage
revenue in your MD&A section to the extent management uses it as a
business or performance measure, however we continue to object to
tabular disclosure of a non-GAAP measure, such as the presentation
in
the "Results of Operations" table on page 30 of your Form 10-K.
In
future filings, please revise your MD&A section to remove net
voyage
revenue from your "Results of Operations" table and revise your
discussion to present the changes in net voyage revenue as an
ancillary or secondary discussion of the reasons for the changes
in
the gross revenue or operating income amounts.

Reports on Form 8-K dated October 28, 2004, January 28, 2005,
April
29, 2005 and August 4, 2005

2. We note your response to comment 7 that you utilize the
distributable cash flow measure as a performance measure to assess
the level of your "cash earnings and your continuing ability to
earn
the amounts you distribute.  However, because the measure
calculates
the amount of cash you are required to distribute to the partners
and
it excludes amounts such as estimated cash capital expenditures,
we
continue to believe that the measure is more appropriately
considered
a liquidity measure.  Please revise future earnings release
announcements to reconcile this non-GAAP measure to the most
comparable GAAP measure, which appears to be cash flow from
operations.

* * * * * * * * * * * * * * * * * * * * * * *

As appropriate, please file your response to these comments via
EDGAR
within 10 business days or tell us when you will provide us with a
response.  Please furnish a cover letter that keys your responses
to
our comments and provides any requested supplemental information.

You may contact Claire Erlanger at 202-551-3301 or me at 202-551-
3813
if you have questions.

								Sincerely,

								Linda Cvrkel
								Branch Chief
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Mr. John J. Nicola
K-Sea Transportation Partners LP
November 17, 2005
Page 1

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