April 28, 2005
via U.S. Mail

Kathleen L. Quirk
Senior Vice President and Treasurer
McMoRan Exploration Co.
1615 Poydras Street
New Orleans, Louisiana 70112


Re:	McMoRan Exploration Co.
		Form S-3/A filed March 29, 2005
	File No. 333-121779

	Form 10-K for the fiscal year ended December 31, 2004
	Filed March 15, 2005

	Response Letter dated April 19, 2005

Dear Ms. Quirk:

      We have reviewed the above filing and response letter and
have
the following comment.  We have limited our review to the areas
commented on below.  Where indicated, we think you should revise
your
documents in response to these comments.  If you disagree, we will
consider your explanation as to why our comment is inapplicable or
revision is unnecessary.  Please be as detailed as necessary in
your
explanation.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  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.

Engineering Comments

10-K as of December 31, 2004
filed on March 15, 2005


Supplementary Oil and Gas Information

	Standardized Measure of Discounted Future Net Cash Flows

1. With regards to response number 4 of your letter dated April
19,
2005, please confirm that your methodology complies with
paragraphs
26 and 30 of FASB 69 concerning the Standardized Measure.  FASB
states that future income tax calculations should relate only to
the
enterprise`s proved oil and gas reserves.  Tax loss carryovers
from
operations or businesses other than oil and gas should not be
included in the Standardized Measure calculation.  On a
supplemental
basis, please specifically identify the part of your operations
that
has sustained the cumulative tax loss carryforwards referenced in
your response.  We may have additional comments.

Closing Comments
	As appropriate, please respond to this letter within 10
business
days or tell us when you will provide us with a response.
Detailed
cover letters greatly facilitate our review.  Please file your
cover
letter on EDGAR.  Please understand that we may have additional
comments after reviewing your response to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging 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 adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

	Please direct all engineering questions to James Murphy,
Petroleum Engineer, at (202) 942-2935.  Please direct all other
questions to Mellissa Campbell Duru, at (202) 942-1930, or in her
absence, to the undersigned at (202) 942-1870.  Direct all
correspondence to the following ZIP code:  20549-0405.

							Sincerely,


							H. Roger Schwall
							Assistant Director
cc: 	via facsimile
	Douglas Currault II, Esq.
	Jones, Walker, Waechter
      Poitevent, Carriere & Denegre, L.L.P
	504-589-8412 (fax)

	H. Schwall
      M.Duru
      J. Murphy
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McMoRan Exploration Co.
April 28, 2005
page 1



UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE