August 28, 2006

Via U.S. Mail and Facsimile (403-264-0251)

Hank B. Swartout
Chairman and Chief Executive Officer
Precision Drilling Trust
4200-150 6th Avenue, S.W.
Calgary, Alberta, Canada T2P 3Y7

	Re:	Precision Drilling Trust
		Form 40-F for the Fiscal Year Ended December 31, 2005
		Filed March 31, 2006
		File No. 1-14534

Dear Mr. Swartout:

      We have limited our review of your Form 40-F for the fiscal
year ended December 31, 2005 to disclosure relating to your
contacts
with a country that has been identified as a state sponsor of
terrorism, and we have the following comments.  Our review with
respect to this issue does not preclude further review by the
Assistant Director group with respect to other issues.  At this
juncture, we are asking you to provide us with supplemental
information, so that we may better understand your disclosure.
Please be as detailed as necessary in your response. 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
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General
1. We note the statement on page 8 of the Form 40-F that, as a
result
of the divestiture of your energy services segment and your
international drilling business, you now derive 100 percent of
your
revenue from the Canadian market.  It appears from your website
that
you may have direct or indirect operations in Syria, a country
identified as a state sponsor of terrorism by the U.S. State
Department and subject to U.S. economic sanctions.  Please clarify
for us whether you currently have operations in Syria.  Describe
for
us in reasonable detail your past, and any current and
anticipated,
direct or indirect business activities in or contacts with Syria,
whether through subsidiaries, affiliates, joint ventures, or other
direct or indirect arrangements.  Describe any technologies,
products, equipment, and services you have sold or otherwise
distributed into Syria.  Describe the extent to which your
dealings
have been with the government of Syria, or entities affiliated
with
or controlled by it.
2. Please discuss the materiality of the operations or other
contacts
described in response to the foregoing comment, and whether they
constitute a material investment risk for your security holders.
You
should address materiality in quantitative terms, including the
dollar amounts of any associated revenues, assets, and
liabilities.
Please also address materiality in terms of qualitative factors
that
a reasonable investor would deem important in making an investment
decision, including the potential impact of corporate activities
upon
a company`s reputation and share value.
We note, for example, that Arizona and Louisiana have adopted
legislation requiring their state retirement systems to prepare
reports regarding state pension fund assets invested in, and/or
permitting divestment of state pension fund assets from, companies
that do business with countries identified as state sponsors of
terrorism.  The Pennsylvania legislature has adopted a resolution
directing its Legislative Budget and Finance Committee to report
annually to the General Assembly regarding state funds invested in
companies that have ties to terrorist-sponsoring countries.  The
Missouri Investment Trust has established an equity fund for the
investment of certain state-held monies that screens out stocks of
companies that do business with U.S.-designated state sponsors of
terrorism.  Your materiality analysis should address the potential
impact of the investor sentiment evidenced by such actions
directed
toward companies having operations in, or other business contacts
with, Syria.

* * * * *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response letter on EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the 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 the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

      Please understand that we may have additional comments after
we
review your response to our comment.  Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments or our review.  You may also contact me at (202) 551-
3470.

								Sincerely,



								Cecilia D. Blye, Chief
								Office of Global Security
Risk

cc: 	Roger Schwall
		Assistant Director
		Division of Corporation Finance







Hank B. Swartout
Precision Drilling Trust
August 28, 2006
Page 1