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      EPPH Correspondence 09-12-2005

        September
          12,
          2005

        Ms.
          Jill S.
          Davis

        United
          States
          Securities and Exchange Commission

        450
          Fifth Avenue,
          N.W.

        Washington,
          D.C.
          20549

                    Re:

                    El
                      Paso
                      Production Holding Company

                    Form
                      10-K for
                      Fiscal Year Ended December 31, 2004

                    Filed
                      March
                      31, 2005

                    Forms
                      10-Q
                      for Fiscal Quarters Ended

                    March
                      31,
                      2005 and June 30, 2005

                    Filed
                      May 12,
                      2005 and August 8, 2005

                    File
                      No.
                      333-106586

        Dear
          Ms.
          Davis:

        We
          are in receipt
          of your letter dated August 31, 2005, commenting on the above referenced
          documents. Below are the comments contained in your letter followed by
          our
          responses. In preparing our responses, we acknowledge the
          following:

                -

                  We
                    are
                    responsible for the adequacy and accuracy of the disclosure in
                    our
                    filings;

                -

                  Staff
                    comments or changes to disclosure in response to staff comments
                    do not
                    foreclose the Commission from taking any action with respect
                    to our
                    filings; and

                -

                  We
                    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.

        Form
          10-K for
          the Fiscal Year Ended December 31, 2004

        Quantitative
          and
          Qualitative Disclosures about Market Risk, page 23

                1.

                  Please
                    expand
                    on your disclosure to clearly indicate whether or not the sensitivities
                    relate to trading or non-trading activities. Note that you are
                    required to
                    address each market risk for both trading and non-trading activities.
                    Refer to Item 305(a) of Regulation
                    S-K.

        Response

        We
          do not currently
          engage in any trading activities. As a result, there is no need to distinguish
          between trading and non-trading activities in our disclosures in item 7A.
          Instead, we make statements such as, “we attempt to mitigate our price risk
          through the use of derivative swap contracts” and “we hedge our natural gas
          production through El Paso Marketing”. We believe these statements are clear as
          to the type of derivative activities we engage in, particularly when read
          in
          context with the other disclosures on derivatives that are included in
          our
          MD&A. Therefore, the distinction was not added. Given your comment, however,
          we will clarify future filings by adding the phrase “non-trading” to disclosures
          in this area to make it entirely clear as to the types of activities we
          conduct.

        Note
          4.
          Financial Instruments and Price Risk Management Activities, page
          35

                2.

                  We
                    note the
                    line item “Net
                    liabilities
                    from price risk management activities” included in the tabular
                    presentation of the carrying amounts and estimated fair values
                    of your
                    financial instruments as of December 31, 2004 and 2003. We note
                    that these
                    amounts correspond to the sum of the current and long-term liability
                    amounts reflected on the face of your consolidated balance sheets.
                    Please
                    confirm, if true, that the amounts reflected on your balance
                    sheets are
                    indeed net
                    balances and
                    explain why this presentation is appropriate. We note your related
                    disclosure on page 36. Specifically address FIN 39 in your
                    response.

        Response

        The
          amounts
          included in Note 4 are not “Net” of any derivative assets and should correctly
          correspond to the sum of our current and non-current price risk management
          liabilities. The “Net” designation is one that applies to a number of our other
          registrants and is a general description of the derivatives we hold. However,
          we
          acknowledge that the use of the word “net” is confusing, and we will remove such
          designation in future filings when the balance solely consists of liabilities
          or
          assets. We conduct all our derivative activities through a single counterparty,
          El Paso Marketing. Under our contract with El Paso Marketing, we have a
          right to
          offset our gain positions and loss positions. Therefore, assets and liabilities
          may be properly netted under the provisions of FIN 39, resulting in a “net
          asset” or “net liability” position.

        Report
          of
          Independent Registered Public Accounting Firm, page 49

                3.

                  Please
                    request your auditors to revise their report to include the name
                    of their
                    audit firm and a conformed signature such that the report fully
                    complies
                    with Article 2 of Regulation S-X.

        Response

        This
          was a
          typographical error. We have the original report in our Company files.
          As a
          result, we respectfully request that we not be obligated to amend the current
          filing for the correction of this oversight, or be allowed to include the
          report
          with the name of the audit firm and a conformed signature in a Form 8-K
          filing.

        General

        Should
          you have any
          further questions regarding our responses to your comments or need further
          information to assist in your review, please contact me at (713) 420-3775,
          or
          Frank Olmsted, Director of Financial Reporting, at (713)
          420-3707.

                Sincerely,

               /s/
                Lisa
                A. Stewart

                Lisa
                  A.
                  Stewart

                President
                  and
                  Chief Executive Officer

              El
                Paso Production Holding
                Company