Mail Stop 0407

      							June 20, 2005

Via U.S. Mail and Fax
Mr. Kendall W. Cowan
Chief Financial Officer
Alamosa Holdings, Inc.
5225 South Loop 289, Suite 120
Lubbock, TX 79424

	RE:	Alamosa Holdings, Inc. and Alamosa (Delaware), Inc.
      Form 10-K for the fiscal year ended December 31, 2004
		Filed March 3, 2005 and March 24, 2005

		Form 10-Q for the fiscal quarter ended March 31, 2004
		File Nos. 001-16793 and 001-15657

Dear Mr. Cowan:

We have reviewed your supplemental response letter dated May 16,
2005
as well as your filings and have the following comments.  As noted
in
our comment letter dated April 7, 2005 we have limited our review
to
your financial statements and related disclosures and do not
intend
to expand our review to other portions of your documents.

Form 10-K for the year ended December 31, 2004

Item 7.  Management Discussion and Analysis, page 31

Critical Accounting Policies, page 32

Long-lived asset recovery, page 34

1. We note your response to comment 2 however we continue to
question
your policies for recognition and measurement of impairment of
long-
lived assets.  We note prior to their acquisition, the long-lived
assets of Roberts Wireless Communications, L.L.C., Washington
Oregon
Wireless, L.L.C., Southwest PCS Holdings, Inc. and AirGate PCS,
Inc.
all had identifiable cash flows that were independent of the cash
flows of the other assets liabilities of Alamosa Holdings, Inc.,
included roaming revenues.  Regarding your last bullet, the
centralization of administrative functions should not impact your
grouping of long-lived assets.  When measuring impairment of the
long-lived assets used in your centralized administrative
functions,
it appears you should use an entity wide asset grouping consistent
with the guidance in paragraph 11 of SFAS No. 144.

Consolidated Statements of Operations, page F-6

2. We refer to your response to comment 3.  In addition to
including
the caption "excluding depreciation shown separately below",
confirm
for us in your response letter that you will also include the
amount
of depreciation that is excluded from the respective line item in
future filings.  Further, please note that SAB Topic 11:B does not
require the caption "exclusive of depreciation shown separately
below" to be included beside the "Selling and marketing" line item
and the "General and administrative expenses" line item.

Note 3. Summary of Significant Accounting Policies, page F-10

Revenue Recognition, page F-11

3. We refer to your response to comment 6.  Please tell us in your
response letter whether you expense direct and incremental costs
of
activating new wireless subscribers in an amount equal to the
activation revenue allocated to the delivered handsets.  If not,
tell
us why you believe it is appropriate to only relate the activation
costs to the activation revenue allocated to the service contract.
Reference all pertinent, authoritative GAAP accounting literature
in
your response.

Goodwill and intangible assets, page F-12

4. Identify for us in your response letter the reporting unit(s)
that
will be used for testing the goodwill acquired in the acquisition
of
AirGate PCS, Inc. for impairment.  Explain to us the basis for
management`s conclusions.

Note 4. Accounts Receivable, page F-15

5. We note your response to comment 8.  In future filings please
disclose your basis for presenting the Sprint roaming receivable
net
of amounts due from Sprint.

Note 8. Leases, page F-19

6. We refer to your response to comment 9 in which you state
"Certain
of these operating lease arrangements include escalation
provisions,
which in accordance with SFAS 13 (as amended by SFAS 98), must be
straight-lined over the expected term of the lease, including
renewal
options that are reasonably assured to occur."  Please tell us in
your response letter the specific guidance of SFAS 13 that
supports
the inclusion of optional renewal periods that are reasonably
assured
as part of the lease term.  Tell us if your leases contain
provisions
indicating guarantees of lessor debt, bargain purchase options,
renewal provisions at the option of the lessor, or specific
monetary
penalties for non-renewal, all of which would allow the use of
renewal periods as part of the lease term in accordance with
paragraph 5(f) of SFAS 13.

Note 15. Sprint Agreements, page F-29

7. We refer to your response to comment 10.  Please tell us in
your
response letter whether the per-activation fee discussed in this
footnote is the same as the direct and incremental costs of
activating new wireless subscribers discussed in your response to
comment 6.  If so, please justify further your conclusion that it
is
appropriate to not include these costs that are directly
attributable
to the generation of revenue in the "cost of service and
operation"
and the "cost of products sold" line items.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  You may contact
Adam Washecka, Staff Accountant, at (202) 551-3375 or Robert S.
Littlepage, Jr., Accounting Branch Chief, at (202) 551-3361 if you
have questions regarding comments on the financial statements and
related matters.  Please contact me at (202) 551-3810 if you have
any
other questions.

							Sincerely,


							Larry M. Spirgel
							Assistant Director




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Mr. Kendall W. Cowan
Alamosa Holdings, Inc.
June 20, 2005
Page 3