Pacific Coast Oil Trust

919 Congress Avenue, Suite 500

Austin, Texas 78701

August 21, 2013

Via EDGAR and Facsimile

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Attn: Anne Nguyen Parker, Branch Chief

Re: Form 10-K for Fiscal Year Ended December 31, 2012

Filed March 29, 2013

File No. 001-35532

Ladies and Gentlemen:

This letter sets forth the responses of Pacific Coast Oil Trust (the “Trust”) to the comments provided by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in its comment letter dated August 9, 2013 (the “Comment Letter”) with respect to the Form 10-K for fiscal year ended December 31, 2012 filed by the Trust on March 29, 2013, File No. 001-35532. For your convenience, we have repeated each comment of the Staff exactly as given in the Comment Letter, and set forth below each such comment is our response.

Form 10-K for Fiscal Year Ended December 31, 2012

Item 2. Properties, page 38

Reserves, page 38

1. We note your response to prior comment 2 in our letter dated July 5, 2013. Please note the disclosure required by Item 1204 of Regulation S-K regarding production by final product sold and average sales price and average production cost per unit should be provided on an annual basis. Please revise your disclosure accordingly.

Response: We acknowledge the Staff’s comment and intend to comply with this comment in future Form 10-Ks. For example, we anticipate that our 2013 Form 10-K will include 2012 disclosure substantially similar to the following, as well as comparable disclosure for 2013:

August 21, 2013

Page 2 of 3

The following table displays PCEC’s underlying sales volumes, average sales prices and production costs for the Underlying Properties, representing the amounts included in the net profits calculation for distributions paid from May 8, 2012 to December 31, 2012:

	Developed Properties						Remaining Properties
Month of Production	Underlying Sales Volumes (Boe) (a)		Average Price (per Boe)		Production Cost (per  Boe)		Underlying Sales Volumes (Boe) (b)		Average Price (per Boe)		Production Cost (per  Boe)
April		110,620		111.17		31.85		—		—		—
May		110,680		100.82		35.76		—		—		—
June		106,568		89.33		32.55		1,857		88.22		31.72
July		107,019		93.53		33.26		5,110		92.54		27.64
August		111,562		98.28		35.52		3,408		99.32		51.14
September		106,691		101.56		38.56		8,298		101.69		28.76
October		106,310		99.43		31.54		17,099		96.45		15.18
Total — 2012		759,450		99.23		34.15		35,772		96.95		24.40

(a) Crude oil sales represented 97% of total sales volumes from the Developed Properties.

(b) Crude oil sales represented 100% of total sales volumes from the Remaining Properties.

In connection with the above responses to the Staff’s comments, we acknowledge that:

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

• 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 Trust may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

[Signature Page Follows]

August 21, 2013

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Please direct any questions or comments regarding the foregoing to the undersigned or to Sean T. Wheeler at Latham & Watkins LLP at (713) 546-7418.

Very truly yours,
PACIFIC COAST OIL TRUST
By: The Bank of New York Mellon Trust
	Company, N.A., as Trustee
By:	/s/ Sarah Newell
	Sarah Newell
	Vice President

Cc: Sean T. Wheeler

Latham & Watkins LLP

Thomas Adkins

Bracewell & Giuliani LLP