UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE

Mail Stop 5546
								August 18, 2006

Via Facsimile (86-10) 848 86 260 and US Mail

Chen Geng
Chairman of the Board of Directors
PetroChina Company Limited
16 Andelu
Dongcheng District
Beijing, 100011
The People`s Republic of China

	Re:	PetroChina Company Limited
		Form 20-F for the Fiscal Year Ended December 31, 2005
		Filed June 20, 2006
		Form 6-K filed June 30, 2005
 		Response Letter Dated July 31, 2006
      File No. 1-15006

Dear Mr. Geng:

      We have reviewed your response dated July 31, 2006 and have
the
following comments.  Please be as detailed as necessary in your
response.  After reviewing this information, we may raise
additional
comments.  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. You state that you account for China National United Oil
Corporation ("China Oil") on the equity basis in your consolidated
financial statements.  Please tell us the nature of your
affiliated
relationship with China Oil, including the percentage of voting
shares held by you and any control you exercise through
directorships
or shared senior management.
2. You indicate that the revenues generated from your indirect
contact with China Oil are not material to your financial
performance.  Please quantify the revenues you recognize that are
attributed to China Oil, and advise us whether you maintain a
financial barrier between you and China Oil`s Sudanese operations
or
otherwise have taken steps to ensure that your revenues from China
Oil are derived only from that affiliate`s non-Sudanese
operations.
3. Advise us whether the sale of Sudanese oil by China Oil
conforms
with the carve-out of Sudanese operations as set forth in section
2C
of the Form 6-K and the definitions of "Businesses" and "Specified
Areas" in the Form 6-K.
4. You state that you do not know whether any dividends, loans or
payments to CNPC have been used to fund operations in Iran, Syria
or
Sudan.  It appears, therefore, that financial transfers to your
controlling shareholder may fund operations in countries
identified
as terrorist-sponsoring states by the U.S. State Department.
Please
expand your materiality analysis to take into account such
indirect
contacts.
5. You state that you believe that neither your indirect contacts
with Sudan nor CNPC`s operations in Iran, Syria and Sudan have had
any adverse impact on your business reputation or share value.
Please discuss the principal factors underlying your belief.  In
this
regard, we note published reports that certain institutional
investors, including Harvard University, Stanford University and
the
California State Teachers` Retirement System, have decided to
divest
your securities due to your ties to Sudan and CNPC`s activities in
Sudan and other terrorist-sponsoring states.

      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.  Please contact James Lopez at (202)
551-
3536 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
Chen Geng
PetroChina Company Limited
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