Companhia Energética de Minas Gerais — CEMIG

January 23, 2015

Via EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Attention: William H. Thompson

Accounting Branch Chief

Re: Companhia Energética de Minas Gerais - CEMIG

Form 20-F for the Fiscal Year Ended December 31, 2013

Filed April 30, 2014

File No. 1-15224

Dear Mr. Thompson:

Set forth below, please find our response to your letter dated December 22, 2014 relating to CEMIG’s Form 20-F for the year ended December 31, 2013 (the “Form 20-F”). To assist in the Staff’s review of our responses, we precede the response below with the text (in bold type) of the comment as stated in your letter. We believe that we have replied to your comments in full. As requested, this letter is being filed on EDGAR as correspondence.

Capitalized terms used in the responses set forth below and not otherwise defined herein have the meanings set forth in the Form 20-F. All financial information is presented in millions of Brazilian Reais, unless otherwise stated.

Form 20-F for Fiscal Year Ended December 31, 2013

Item 4. Information on the Company, page 20

Capital Expenditures, page 31

1. Please show us how to reconcile total capital expenditures to the disclosures in the notes to the financial statements.

CEMIG advises the Staff that capital expenditures is comprised of the following items included in cash flows from investing activities in our Statements of Cash Flows:

CASH FLOWS FROM INVESTMENT ACTIVITIES that REPRESENT CAPITAL EXPENDITURES:	2013			2012			2011
Financial assets		(91	)		(107	)		(57	)
Acquisition of jointly-controlled subsidiary. net of cash acquired		(94	)		—			—
Cash injection in Investees		(355	)		(396	)		(879	)
PP&E		(69	)		(109	)		(95	)
Intangible assets		(908	)		(1,263	)		(1,183	)
Other (rounding difference)		(1	)		—			—
Total capital expenditures presented on page 31 of CEMIG’s 2013 Form 20-F		(1,518	)		(1,875	)		(2,214	)

Item 5. Operating and Financial Review and Prospects, page 71

2. Please provide the disclosures required by Item 5(e) of Form 20-F or tell us why such disclosures are not required.

CEMIG advises the Staff that it does not have any off-balance sheet arrangements that would require disclosure pursuant to Item 5(e) of Form 20-F.

Consolidated Statements of Cash Flow, page F-10

3. Please tell us your consideration of disclosing investing and financing transactions that do not require the use of cash in accordance with paragraph 43 of IAS 7 or where such disclosures can be found.

CEMIG advises the Staff that, in accordance with paragraph 43 of IAS 7, the investing and financing transactions that do not require the use of cash relate primarily to costs of loans and financing linked to works that were capitalized as Intangible Assets and transfers of Intangible assets “under construction” to financial assets as disclosed in Note 17 to CEMIG’s 2013 Financial Statements. In response to the staff’s comment, CEMIG will revise its Statements of Cash Flow in its 2014 Annual Report on Form 20-F to disclose these items as transactions that do not require the use of cash.

4. Please show us how to reconcile the additions to PP&E to your disclosure in note 16. Please also show us how to reconcile the decrease in the accounts receivable from Minas Gerais state government for 2012 to your disclosure in note 12.

Additions to PP&E

In response to the Staff’s comment, below is a rollforward of PP&E from December 31, 2012 to December 31, 2013 to separately display additions and transfers, which historically have been grouped together:

Consolidated	2012 balance restated		Additions		Transfers		Written down		Depreciation		2013 balance
In service
Land		380		4		—		—		-7		378
Reservoirs. dams and water courses		2,552		8		—		—		-165		2,395
Buildings. works and improvements		743		18		—		-3		-46		712
Machinery and equipment		2,198		19		35		-4		-169		2,079
Vehicles		6		8		—		—		-2		12
Furniture and utensils		1		1		—		—		—		2
		5,880		58		35		-7		-389		5,578
Under construction		229		11		—		—		—		239
Net PP&E		6,109		69		35		-7		-389		5,817

2

CEMIG also advises the Staff that there were no transfers to Property, Plant and Equipment from December 31, 2011 to December 31, 2012. Therefore, the amount included as additions in note 16 agrees with the amount disclosed in the Statements of cash flow for the year ended December 31, 2012. The difference of 1 refers to rounding.

In response to the Staff’s comment, CEMIG will separately disclose additions and transfers to PP&E in the Financial Statements included in its 2014 Annual Report on Form 20-F.

Decrease in the accounts receivable from Minas Gerais state government for the year ended December 31, 2012

CEMIG advises the Staff that the reconciliation of the amount of R$1,498 million related to a decrease in the accounts receivable from Minas Gerais state government presented in Consolidated Statements of Cash Flow for the year ended in December 31, 2012 is presented in the table below:

Total of decrease in the accounts receivable from Minas Gerais State Government	Consolidated
Net amounts settled by Minas Gerais State		(1,343	)
Net amounts received from FIDC		(155	)
Total		(1,498	)

CEMIG advises the Staff that the disclosures in Note 12 reflect certain transaction relating to the Credit Rights Investment Fund (FIDC). Since the FIDC was consolidated in CEMIG’s financial statements, these transactions are treated in consolidated financial statements, as a reduction of Company’s accounts receivable from Minas Gerais State Government. In order to demonstrate how CEMIG arrived at the cash received from the Minas Gerais state government for the year ended December 31, 2012, below is a rollforward of the accounts receivable balance on a consolidated basis for the respective year:

Accounts receivable from Minas Gerais state government	Consolidated
Balance on December 31, 2011		1,830
Monetary updating of accounts receivable from Minas Gerais state government		165
Income and social contribution taxes and taxes on financial transactions, withheld		(55	)
Monetary updating of the contract as per conditions agreed with Minas Gerais State		2,383
Retained by Minas Gerais State to settle CEMIG’s litigation with federal government re CRC Account		(403	)
Total of decrease in the accounts receivable from Minas Gerais State Government		(1,498	)
Balance on December 31, 2012		2,422

Explanatory Notes to the Consolidated Financial Statements, page F-12

2.5 New Accounting pronouncements adopted starting in 2013, page F-19

5. We note that your adoption of IFRS 11 resulted in accounting for investments in joint ventures and jointly controlled entities using the equity method instead of the proportional consolidation method you used prior to the adoption of IFRS 11. Please tell us in sufficient detail how you determined these joint arrangements qualified as joint ventures as opposed to joint operations. Ensure your analysis discusses the structure and form of the arrangements and the involved parties’ rights and obligations arising from the arrangements.

3

CEMIG advises the Staff that it determined that its joint arrangements qualified as joint ventures based on the characteristics presented below, which are based on the requirements of IFRS 11:17 and B15:

• The joint arrangements previously accounted for using the proportional consolidation method are conducted through separate legal entities.

• According to the Brazilian Corporate Law, CEMIG does not have any direct rights or liabilities relating to the individual assets and liabilities of these entities. CEMIG only has rights to the net assets of these entities.

• The terms of the arrangements also stipulate that CEMIG does not have rights to assets or obligations relating to the liabilities of these entities.

• The joint venture activities were not primarily designed for the provision of output to CEMIG and the other venturers. The revenues of these entities are primarily derived from unrelated parties.

• The main cash flow source of these entities comes from their own operations. The entities are not dependent on cash flow contributions of CEMIG or the other venturers.

• According to Brazilian Corporate Law, CEMIG is liable only to the extent of its investments in each arrangement. These entities are directly liable for their debts, obligations and claims related to their activities.

• CEMIG and the other venturers share profits and dividends according to their respective ownership interest in each entity, as required by Brazilian Corporate Law.

6. It does not appear that you disclosed the impact of the adoption IFRS 11 and IAS 19 on each line item in the statements of financial position, statements of income and statements of cash flow or basic and diluted profit per preferred and common share as required by paragraph 28(f) of IAS 8. Please revise or advise.

CEMIG advises the Staff that the information disclosed in Note 2 to CEMIG’s 2013 financial statements, pages F-20 to F-22, describes the main effects of the adoption IFRS 11 and IAS 19 on its financial statements. CEMIG further advises that the adoption IFRS 11 and IAS 19 did not change CEMIG’s basic and diluted profit per preferred and common share.

7. We note that the amounts disclosed in the statement of cash flow for 2012 as reclassified differ from the amounts reflected in the statements of cash flow. Please revise or advise.

4

CEMIG advises the Staff that the correct reclassified amounts are properly disclosed in the statements of cash flow. However, CEMIG included certain incorrect amounts in Note 2 relating to the impacts on the statements of cash flows. In response to the Staff’s comment, CEMIG will revise Note 2 in the Financial Statements included in its 2014 Annual Report on Form 20-F. The corrected amounts that will be included in Note 2 are presented in the table below:

Year ended 12/31/2012	Consolidated
Statement of cash flow	Published			Principles of consolidation			Reclassified
Net cash generated by operational activities		3,278			(449	)		2,829
Net cash from (used in) financing activities		8			(2,116	)		(2,108	)
Net cash used in investment activities		(3,610	)		2,704			(906	)
Net change in cash and cash equivalents		(324	)		139			(185	)
Initial balance of Cash and cash equivalents		2,863			(759	)		2,104
Final balance of Cash and cash equivalents		2,539			(620	)		1,919
Net change in cash and cash equivalents		(324	)		139			(185	)

5. Operational Segments, page F-50

8. We note the information by segment includes a line item for additions to (reduction in) the segment. Please tell us what the additions/reductions reflected in the line item represent and show us how to reconcile the amounts to other disclosures in the notes to financial statements.

CEMIG advises the Staff that additions/reductions reflected in the line item represent capital expenditures less cash received on the disposal of investments. The additions to (reduction in) operational segments is comprised of the following line items from the respective Statements of Cash Flows:

CASH FLOWS FROM INVESTMENT ACTIVITIES	2013			2012		2011
Financial assets		91			107		57
Acquisition of jointly-controlled subsidiary. net of cash acquired		94			—		—
Cash injection in Investees		356			396		879
PP&E		69			109		95
Intangible assets		908			1,263		1,183
Total capital expenditures		1,518			1,875		2,214
Cash received on disposal of investments		(1,691	)		—		—
ADDITIONS TO (REDUCTION IN) OPERATIONAL SEGMENTS		(173	)		1,875		2,214

Additionally, CEMIG advises the Staff that Note 5 includes certain incorrect amounts in the Generation and Other columns of the additions/reductions line item for the year ended December 31, 2012. CEMIG will revise this information in the Financial Statements included in its 2014 Annual Report on Form 20-F.

5

The original amount of R$ 1,473 million disclosed for the year ended December 31, 2012, related to additions to the segment, was adjusted and is properly presented in the table below:

INFORMATION BY SEGMENT. 2012
ITEM	GENERATION		TRANSMISSION		DISTRIBUTION		TELECOM		GAS		OTHER		TOTAL
ADDITIONS TO (REDUCTION IN) THE SEGMENT		473		107		1,229		—		—		66		1,875

9. Please tell us if segment liabilities are reported to and reviewed by the chief operating decision maker and if the measure of segment assets reviewed by the chief operating decision maker include the amount of investment in associates and joint ventures accounted for by the equity method. If so, please disclose segment liabilities and the investment in associates and joint ventures in future filings. Refer to paragraphs 20 and 23 of IFRS 8.

CEMIG advises the Staff that liabilities are not reported by segment to the chief operating decision maker. However, the measure of segment assets reviewed by the chief operating decision maker does include the amount of investments in associates and joint ventures accounted for by the equity method. The investments in associates and joint ventures by segment for 2013, 2012 and 2011 are as follows:

INFORMATION BY SEGMENT. 2013
ITEM	GENERATION		TRANSMISSION		DISTRIBUTION		TELECOM		GAS		OTHER		TOTAL
INVESTMENTS IN ASSOCIATES AND JOINT VENTURES		1,623		2,379		1,191		4		577		387		6,161

INFORMATION BY SEGMENT. 2012
ITEM	GENERATION		TRANSMISSION		DISTRIBUTION		TELECOM		GAS		OTHER		TOTAL
INVESTMENTS IN ASSOCIATES AND JOINT VENTURES		1,135		3,747		1,104		—		508		361		6,855

INFORMATION BY SEGMENT. 2011
ITEM	GENERATION		TRANSMISSION		DISTRIBUTION		TELECOM		GAS		OTHER		TOTAL
INVESTMENTS IN ASSOCIATES AND JOINT VENTURES		772		3,546		1,158		—		513		363		6,351

CEMIG will revise its disclosure to include the investments in associates and joint ventures by segment in its 2014 Annual Report on Form 20-F.

6

3. Principles of Consolidation, page F-40

10. Please tell us why Central Termeletrica de Cogeracao is not included in the tables in note 15.

CEMIG advises the Staff that, as described in Note 1 to CEMIG’s 2013 financial statements, page F-16, CEMIG Comercializadora de Energia Incentivada S.A. was formerly known as Central Termelétrica de Cogeração S.A.

The entity is correctly shown in the tables in Note 15 on page F-70. In the table presented in Note 3 on page F-40, this entity was disclosed under its previous name Central Termelétrica de Cogeração. CEMIG will correct the name of this entity in Note 3 in its 2014 Annual Report on Form 20-F.

15. Investments, page F-66

11. Please tell us how the summarized financial information beginning on page F-70 complies with the information required by paragraphs B12 and B13 of IFRS 12 or revise your disclosure to comply with the disclosure requirements. Please also translate the summarized financial information into English.

CEMIG advises the Staff that certain items required by paragraphs B12 and B13 of IFRS 12 were inadvertently not included in the summarized financial information in Note 15. Following is the summarized financial information in English, including certain line items in bold which were not presented in the footnote included in the Form 20-F. CEMIG will include revised summarized financial information in its 2014 Annual Report on Form 20-F.

CEMIG also advises that additional information regarding the main joint ventures and associations (Ligth and Taesa) is publicly available in English, since these companies are listed and disclose regular information to investors.

7

2013	Gasmig			Transleste			Transirapé			Centroeste			Transudeste			Transchile			Light			Taesa			Axxiom
Assets
Current		368			41			30			61			27			18			3,632			1,680			34
Cash and cash equivalents		—			—			—			—			—			—			546			121			—
Other current assets		368			41			30			61			27			18			3,086			1,559			34
Non-Current		1,401			125			74			—			81			189			9,516			7,537			8
Total Assets		1,769			166			104			61			108			207			13,148			9,217			42
Liabilities
Current		299			9			5			6			4			18			3,313			830			15
Suppliers		—			—			—			—			—			—			907			52			—
Non-Current		541			41			41			20			46			77			6,326			4,061			11
Equity		929			116			58			35			58			112			3,509			4,326			16
Total Liabilities and Equity		1,769			166			104			61			108			207			13,148			9,217			42
Statement of Income
Net Revenue		1,203			33			20			12			20			17			7,765			1,254			38
Total Cost		(956	)		(2	)		(2	)		—			(1	)		(2	)		(4,191	)		(257	)		(28	)
Depreciation and amortization		—			—			—			—			—			—			(351	)		(1	)		—
Gross Profit		247			31			18			12			19			15			3,574			997			10
General and administrative expenses		(48	)		(2	)		(1	)		(2	)		(1	)		(8	)		(2,263	)		—			(7	)
Depreciation and amortization		—			—			—			—			—			—			(40	)		(1	)		—
Net Financial Revenue (Expenses)		(18	)		(3	)		(3	)		(1	)		(3	)		(5	)		(459	)		(229	)		—
Financial revenues		—			—			—			—			—			—			365			196			—
Financial expenses		—			—			—			—			—			—			(824	)		(425	)		—
Operational profit		181			26			14			9			15			2			852			768			3
Income tax and Social Contribution tax		(60	)		(1	)		(1	)		(1	)		(1	)		(1	)		(265	)		121			(1	)
Net Profit for the Period		121			25			13			8			14			1			587			889			2
Statement of Comprehensive Income
Net Profit for the Period		121			25			13			8			14			1			587			889			2
Other Comprehensive Income
Adjustment of actuarial liabilities, net of taxes		—			—			—			—			—			—			95			—			—
Comprehensive Income For The Period		121			25			13			8			14			1			682			889			2

8

2012	Gasmig			Transleste			Transirapé			Centroeste			Transudeste			Transchile
Assets
Current		221			39			25			77			32			15
Non-Current		1,318			123			70			—			79			168
Total Assets		1,574			162			95			77			111			183
Liabilities
Current		273			9			4			13			6			15
Non-Current		509			47			44			22			49			70
Equity		808			106			47			42			56			98
Total Liabilities and Equity		1,574			162			95			77			111			183
Statement of Income
Net Revenue		1,043			30			19			12			19			14
Total Cost		(860	)		(2	)		(2	)		(2	)		(1	)		(6	)
Gross Profit		183			28			17			10			18			8
General and administrative expenses		(93	)		(1	)		(2	)		(1	)		(2	)		(3	)
Net Financial Revenue (Expenses)		33			(4	)		(4	)		—			(4	)		(4	)
Operational profit		123			23			11			9			12			1
Income tax and Social Contribution tax		(26	)		(1	)		(1	)		(1	)		(1	)		—
Net Profit for the Period		97			22			10			8			11			1
Statement of Comprehensive Income
Net Profit for the Period		97			22			10			8			11			1
Other Comprehensive Income		—			—			—			—			—			—
Comprehensive Income For The Period		97			22			10			8			11			1

2012	Light			Taesa			EATE			ECTE			ETEP			ENTE			ERTE			Axxiom
Assets
Current		2,379			3,861			329			157			158			205			62			11
Cash and cash equivalents		230			2,530			—			—			—			—			—			—
Other current assets		2,149			1,331			329			157			158			205			62			11
Non-Current		9,394			5,784			1,271			156			190			385			103			5
Total Assets		11,773			9,645			1,600			313			348			590			165			16
Liabilities
Current		2,179			628			168			36			61			68			41			6
Suppliers		863			43
Non-Current		6,329			4,885			568			159			109			153			40			—
Equity		3,265			4,132			864			118			178			369			84			10
Total Liabilities and Equity		11,773			9,645			1,600			313			348			590			165			16
Statement of Income
Net Revenue		8,021			1,269			295			70			66			154			61			23
Total Cost		(5,954	)		(109	)		(25	)		(5	)		(8	)		(13	)		(32	)		(17	)
Depreciation and amortization		(315	)		(1	)		—			—			—			—			—			—
Gross Profit		2,067			1,160			270			65			58			141			29			6
General and administrative expenses		(920	)		(77	)		—			—			—			—						(5	)
Depreciation and amortization		(43	)		(1	)		—			—			—			—			—			—
Net Financial Revenue (Expenses)		(461	)		(278	)		1			(6	)		(4	)		(15	)		(3	)		—
Financial revenues		199			257			—			—			—			—			—			—
Financial expenses		(660	)		(535	)		—			—			—			—			—			—
Operational profit		686			805			271			59			54			126			26			1
Income tax and Social Contribution tax		(205	)		(220	)		(31	)		(18	)		(8	)		(12	)		(2	)		—
Net Profit for the Period		481			585			240			41			46			114			24			1

9

2012	Light			Taesa		EATE		ECTE		ETEP		ENTE		ERTE		Axxiom
Statement of Comprehensive Income
Net Profit for the Period		481			585		240		41		46		114		24		1
Other Comprehensive Income
Adjustment of actuarial liabilities, net of taxes		(132	)		—		—		—		—		—		—		—
Comprehensive Income For The Period		349			585		240		41		46		114		24		1

12. We note that the table of summarized financial information of equity investees does not include information for Epicares Empreendimentos and Parati, which appear to be material. Please tell us why the summarized financial information for these associates is not included in the table. Refer to paragraph B12 of IFRS 12.

CEMIG advises the Staff that Parati is a special purpose entity that has a direct interest in Light of 6.41%. Although the summarized information of Parati was not included in the table of summarized financial information, the information for Light presented in the summarized financial information table represents both CEMIG’s direct investment in Light and its indirect investment through Parati. CEMIG will include the summarized financial information for Parati separately in its 2014 Annual Report on Form 20-F. Although some information related to Epicares Empreendimentos was presented on page F-67, CEMIG will include the following summarized financial information for this equity investee in its 2014 Annual Report on Form 20-F.

2013	Epícares
Assets
Current		31
Cash and cash equivalents		27
Other current assets		4
Non-Current		186
Total Assets		217
Liabilities
Current		1
Non-Current		1
Equity		215
Total Liabilities and Equity		217
Statement of Income
Net Revenue		35
Total Cost		—
Gross Profit		35
General and administrative expenses		(4	)
Net Financial Revenue (Expenses)		—
Operational profit		31
Income tax and Social Contribution tax		(1	)
Net Profit for the Period		30
Statement of Comprehensive Income
Net Profit for the Period		30
Other Comprehensive Income		—
Comprehensive Income For The Period		30

10

13. It appears that the entities associated with CEMIG Geracao e Transmissao listed in the table on page F-66 in b) are not included in the table on page F-70. Please tell us why.

Although certain information related to the entities associated with CEMIG Geracao e Transmissao was presented on page F-67, CEMIG will revise the summarized financial information of equity investees in its 2014 Annual Report on Form 20-F to include all entities associated with CEMIG Geracao e Transmissao as follows:

2013	Hidrelétrica Cachoeirão			Guanhães Energia		Hidrelétrica Pipoca			Madeira Energia			Lightger			Baguari Energia			Central Eólica Praias de Parajuru			Central Eólica Volta do Rio			Central Eólica Praias de Morgado			Amazônia Energia
Assets
Current		27			24		19			701			21			70			10			30			16			—
Cash and cash equivalents		23			23		14			298			18			27			1			1			2			—
Other current assets		4			1		5			403			3			43			9			29			14			—
Non-Current		93			243		107			19,822			182			239			165			291			169			417
Total Assets		120			267		126			20,523			203			310			175			322			185			417
Liabilities
Current		10			124		12			900			11			18			16			35			18			—
Non-Current		37			5		63			13,197			110			4			83			162			111			—
Equity		73			138		51			6,426			82			288			76			125			56			417
Total Liabilities and Equity		120			267		126			20,523			203			310			175			322			185			417
Statement of Income
Net Revenue		29			—		23			1,301			29			49			30			52			28			—
Total Cost		(5	)		—		(7	)		(682	)		(17	)		(9	)		(14	)		(26	)		(15	)		—
Gross Profit		24			—		16			619			12			40			16			26			13			—
General and administrative expenses		(3	)		—		(1	)		(348	)		(2	)		(27	)		(1	)		(1	)		(1	)		(4	)
Net Financial Revenue (Expenses)		(2	)		—		(4	)		(306	)		(6	)		4			(7	)		(12	)		(9	)		—
Operational profit		19			—		11			(35	)		4			17			8			13			3			(4	)
Income tax and Social Contribution tax		(2	)		—		(1	)		(13	)		(1	)		(6	)		(1	)		(2	)		(1	)		—
Net Profit for the Period		17			—		10			(48	)		3			11			7			11			2			(4	)
Statement of Comprehensive Income
Net Profit for the Period		17			—		10			(48	)		3			11			7			11			2			(4	)
Other Comprehensive Income		—			—		—			—			—			—			—			—			—			—
Comprehensive Income For The Period		17			—		10			(48	)		3			11			7			11			2			(4	)

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2012	Hidrelétrica Cachoeirão			Guanhães Energia		Hidrelétrica Pipoca			Madeira Energia			Lightger			Baguari Energia			Central Eólica Praias de Parajuru			Central Eólica Volta do Rio
Assets
Current		24			5		14			327			33			77			5			15
Cash and cash equivalents		21			5		10			111			18			51			2			9
Other current assets		3			—		4			216			15			26			3			6
Non-Current		96			126		110			15,213			188			255			169			309
Total Assets		120			131		124			15,540			221			332			174			324
Liabilities
Current		9			81		13			1,493			22			49			13			43
Non-Current		44			9		69			9,768			117			3			91			165
Equity		67			41		42			4,279			82			280			70			116
Total Liabilities and Equity		120			131		124			15,540			221			332			174			324
Statement of Income
Net Revenue		29			—		21			342			21			48			22			27
Total Cost		(5	)		—		(5	)		(182	)		(8	)		(5	)		(12	)		(19	)
Gross Profit		24			—		16			160			13			43			10			8
General and administrative expenses		(4	)		—		(1	)		(127	)		(7	)		(11	)		(2	)		(5	)
Net Financial Revenue (Expenses)		(3	)		—		(5	)		(293	)		1			4			(8	)		(14	)
Operational profit		17			—		10			(260	)		7			36			—			(11	)
Income tax and Social Contribution tax		(1	)		—		(1	)		2			(5	)		(12	)		(1	)		(1	)
Net Profit for the Period		16			—		9			(258	)		2			24			(1	)		(12	)
Statement of Comprehensive Income
Net Profit for the Period		16			—		9			(258	)		2			24			(1	)		(12	)
Other Comprehensive Income		—			—		—			—			—			—			—			—
Comprehensive Income For The Period		16			—		9			(258	)		2			24			(1	)		(12	)

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2012	Central Eólica Praias de Morgado			Amazônia Energia			EBTE
Assets
Current		15			1			66
Cash and cash equivalents		1			—			10
Other current assets		14			1			56
Non-Current		180			272			464
Total Assets		195			273			530
Liabilities
Current		24			—			46
Non-Current		116			—			170
Equity		55			273			314
Total Liabilities and Equity		195			273			530
Statement of Income
Net Revenue		29			—			50
Total Cost		(12	)		(1	)		(6	)
Gross Profit		17			(1	)		44
General and administrative expenses		(4	)		(1	)		(5	)
Net Financial Revenue (Expenses)		(10	)		—			(12	)
Operational profit		3			(2	)		27
Income tax and Social Contribution tax		(1	)		—			(9	)
Net Profit for the Period		2			(2	)		18
Statement of Comprehensive Income
Net Profit for the Period		2			(2	)		18
Other Comprehensive Income		—			—			—
Comprehensive Income For The Period		2			(2	)		18

16 – Property, Plant and Equipment, page F-77

14. Please tell us your consideration of separately disclosing additions and transfers. Refer to paragraph 73(e) of IAS 16.

As described in our response to the Staff’s comment 4, CEMIG will separately disclose additions and transfers in Property, Plant and Equipment in its 2014 Annual Report on Form 20-F.

22. Post-Retirement Liabilities, page F-89

15. Please tell us your consideration disclosing comparative information regarding changes in the present value of the defined benefit obligation, fair value of plan assets plan assets and post-employment benefits expense for each year presented. Please refer to paragraph 38 of IAS 1 and paragraphs 140 and 141 of IAS 19.

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CEMIG advises the Staff that rollforward information regarding changes in the present value of the defined benefit obligation, fair value of plan assets and post-employment benefits expense from 2012 to 2013 are presented in the Note 22 to CEMIG’s 2013 financial statements.

The changes in the present value of the defined benefit obligation, fair value of plan assets and post-employment benefits expense from 2011 to 2012 were not presented in CEMIG’s 2013 financial statements. However, this information, as shown below, is disclosed in the note 21 to CEMIG’s 2012 financial statements.

	Pension plans and retirement supplement plans			Health Plan			Dental Plan			Life Insurance
Defined-benefit obligation as of 12/31/2011		7,254			626			18			540
Cost of current service		8			11			—			6
Interest on the actuarial obligation		703			61			2			54
Actuarial losses (gains) recognized		1,780			181			3			148
Benefits paid		(554	)		(59	)		(1	)		(12	)
Defined-benefit obligation as of 12/31/2012		9,191			820			22			736

	Pension plans and retirement supplement plans
Fair value of the plan assets of the plan as of 12/31/2011		6,893		355
Expected return		1,678		105
Employer Contributions		125		37
Benefits paid		(554	)	(70	)
Fair value of the plan assets of the plans as of 12/31/2012		8,142		427

	Pension plans and retirement supplement plans			Health Plan		Dental Plan			Life Insurance
Current service cost		8			11		—			6
Interest on the actuarial obligation		703			61		2			54
Expected return on plan assets		(735	)		—		—			—
Actuarial losses (gains) recognized		—			—		(1	)		1
Expense in 2012 as per the actuarial report		(24	)		72		1			61
Adjustment related to debt with FORLUZ		117			—		—			—
Total expense recorded in 2012		93			72		1			61

CEMIG will disclose comparative information regarding changes in these items for each of the periods presented in its 2014 Annual Report on Form 20-F.

16. Please tell us what consideration you gave to disclosing a sensitivity analysis for each significant actuarial assumption, the methods and assumptions used in preparing the sensitivity analyses and the limitations of those methods and changes from the previous year in the methods and assumptions used in preparing the sensitivity analyses. Refer to paragraph 145 of IAS 19.

14

In response to the Staff’s comment, the following is a sensitivity analysis of the main actuarial assumptions to determinate the defined benefit obligation:

Effects in Defined-benefit obligation	Pension plans and retirement supplement plans		Health Plan		Dental Plan		Life insurance
Mortality Table smoothed in 1 year		349		14		1		25
Discount rate decreased by 1 %		681		120		4		109

In the presentation of the sensitivity analysis, the present value of the defined benefit obligation was calculated using the projected unit credit method at the end of the reporting period, the same method used to calculate the defined benefit obligation recognized in the balance sheet. CEMIG has not made changes to the methods utilized to calculate its post-retirement benefits for the years ended December 31, 2013, 2012 and 2011.

CEMIG will disclose this sensitivity analysis in its 2014 Annual Report on Form 20-F.

29. Financial Instruments and Risks Management, page F-115

17. Please tell us what consideration you gave to disclosing the information required by IFRS 13 for assets measured at fair value on a recurring basis.

CEMIG advises the Staff that, as disclosed in Note 30 to CEMIG’s 2013 financial statements, its principal assets measured at fair value are Financial Assets relating to its concessions, amounting to R$5,559 million, which represents 90% of the total assets measured at fair value. CEMIG advises the Staff that there is no active market for concession assets in Brazil and consequently, these assets are classified as a level 3 instrument. Pursuant to paragraph 91 of IFRS 13, the effects of the measurements on profit were presented in Note 27 to CEMIG’s 2013 financial statements, in the line item “Net updating on the Financial Assets of the concession”.

The main input used by CEMIG and other Brazilian electricity distribution companies to determine the fair value of the financial assets related to its concessions was the New Replacement Value (VNR) of concession infrastructure, according to criteria established in regulations by the Grantor of the concessions, which are based on the fair value of the assets in service belonging to the concession and which will be reversible at the end of the concession, as well as the Weighted Average Cost of Capital (WACC) rate used by the Grantor, which reflects the concessionaire’s return on the concession operations. CEMIG advises the Staff that the both VNR and WACC rates are public information disclosed by the Grantor and by CEMIG.

Considering the Brazilian regulatory framework, CEMIG does not expect a change in the unobservable input used to calculate the fair value. Additional information was provided about such financial instruments in Note 14 to CEMIG’s 2013 financial statements.

The remaining amount of assets measured at fair value is principally related to securities. A general description about the valuation techniques and inputs used to measure those securities is presented in Note 27 to CEMIG’s 2013 financial statements.

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*             *              *

As requested in your letter, CEMIG acknowledges the following:

• CEMIG is responsible for the adequacy and accuracy of the disclosure in the filing;

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

• CEMIG 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.

*             *              *

Should you have any questions about the responses in this letter, kindly contact our outside counsel, Michael Fitzgerald at (212) 318-6988 or Steven Sandretto at (212) 318-6776. In addition, we kindly request that any further correspondence also be faxed to CEMIG at (011) (55) (31) 3506 – 5025.

Very truly yours,

/s/ Luiz Fernando Rolla

Luiz Fernando Rolla

Chief Officer for Finance and Investor Relations

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