El Paso Corporation

1001 Louisiana Street
Houston, Texas 77002

July 11, 2006

VIA FACSIMILE (202) 772-9204

Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attention: Scott M. Anderegg

Re: Registration Statement on Form S-4 (No. 333-134099) of El Paso Corporation

Ladies and Gentlemen:

     On behalf of El Paso Corporation (the “Company”), and pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, the undersigned hereby requests that the effective date of the above referenced Registration Statement on Form S-4 be accelerated to 9:00 a.m., Washington, D.C. time, on Thursday, July 13, 2006, or as soon thereafter as practicable. The Company hereby acknowledges that:

• should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the accuracy and adequacy of the disclosure in the filing; and

• the Company may not assert staff comments or the staff’s declaration of the effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

This request has also been transmitted via EDGAR.

Very truly yours,

El Paso Corporation

By:      /s/ Kelly Jameson                    

Name: Kelly Jameson

Title:   Senior Counsel