Methanex Corporation	1800 Waterfront Centre 200 Burrard Street Vancouver, BC	Telephone: Facsimile:	604-661-2600 604-661-2676
	V6C 3M1	www.methanex.com

January 17, 2014  

Via Edgar

Mr. John Cash

Accounting Branch Chief

United States Securities and Exchange Commission

Washington, D.C. 20549

RE: Methanex Corporation

Form 40-F for the year ended December 31, 2012

Filed March 14, 2013

File No. 0-20115

Dear Mr. Cash:

We have reviewed your comments outlined in your letter of December 17, 2013 relating to the captioned items and offer the following responses.

Form 40-F for the Year Ended December 31, 2012

Exhibit 99.2 – Management’s Discussion & Analysis

Critical Accounting Estimates, page 32

Recoverability of Asset Carrying Values, page 33

SEC Comment:

1. You disclose on page 34 that the post-impairment carrying value of your Chile cash-generating unit, which included a second facility that management was considering for relocation from Chile to Geismar, Louisiana, was $245 million as of December 31, 2012. Your form 6-K filed on April 26, 2013 indicates that you reached a final investment decision to proceed with the relocation of this second methanol plant. Please tell us how you considered if this decision was an impairment indicator which would trigger the need for a recoverability test on the long-lived assets of your Chile cash-generating unit during the year ended December 31, 2013. If so, please describe for us the outcome of this recoverability test. Please refer to paragraphs 12-14 of IAS 36.

Our Response:

We performed the recoverability test at December 31, 2012 in accordance with IAS 36, Impairment of Assets, which measures the recoverable amount of a cash-generating unit as the higher of its estimated fair value less costs to sell or alternatively its value in use. Under paragraph 31 of IAS 36, value in use considers both the present value of the future cash flows expected to be generated from the continuing use of the assets and any fair value expected to be realized upon their completion of use in the cash-generating unit.

At December 31, 2012, the Chile cash-generating unit consisted primarily of three individual but interdependent methanol plants (including the second facility referenced in your comment) on a single site. Our estimate of the present value of the future cash flows expected to be generated from the production of methanol in Chile included an assumption that there would be insufficient natural gas available in future periods to allow us to utilize all three methanol plants at the same time. As a result, our value in use estimate also considered the alternate use of one of the plants. Of the $245 million recoverable value of the Chile cash generating unit at December 31, 2012, $170 million was our estimate of the present value of future cash flows expected to be generated from the production of methanol in Chile and $75 million related to the methanol plant that management believed was likely to be relocated in the near term.

The final investment decision made in April 2013 to relocate a second plant to Louisiana did not represent an impairment indicator of the Chile cash-generating unit since our estimate of the future cash flows was based on the assumption that methanol production in Chile would be limited to the operation of one methanol plant at any time and there had been no significant changes in other assumptions. In April 2013, the carrying value of the methanol facility to be relocated to Louisiana was removed from the Chile cash-generating unit and included in the Louisiana cash-generating unit.

SEC Comment:

2. In light of your decision to relocate a second plant to Geismar, Louisiana, please quantify for us the percentage by which the estimated pre-tax fair value of your Chile cash-generating unit exceeded its carrying value as of the most recent date available. If the fair value did not substantially exceed the carrying value, please show us how you will enhance your disclosure in future filings by providing the following additional disclosures for your Chile cash-generating unit:

• Disclose the percentage by which the estimated pre-tax fair value exceeds the carrying value;

• Provide a description of the key assumptions that drive the estimated pre-tax fair value; and

• Provide a discussion of the uncertainty associated with the key assumptions, including a discussion if the assumptions used in the cash flow model materially deviate from your historical results.

Please note that you previously agreed to provide these disclosures in your response letter dated January 11, 2013.

Our Response:

As noted in response to comment 1, we concluded that the final investment decision to relocate a second methanol plant from Chile to Geismar, Louisiana did not represent an impairment indicator of the cash-generating unit since the recoverability test performed at December 31, 2012 assumed that methanol production in Chile would be limited to the operation of one methanol plant at any time and there had been no significant changes in other assumptions.

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At December 31, 2013, our Chile cash-generating unit consists primarily of the two remaining methanol plants in Chile. As a consequence of the continued uncertain outlook for the future supply of natural gas feedstock to our Chile operations, we concluded that it was prudent to perform a recoverability test of the Chile cash-generating unit at December 31, 2013. Based on the preliminary results, we believe that the recoverable amount is neither less than nor substantially in excess of the assets current carrying value. As a result, in the Management’s Discussion and Analysis of our Form 40-F for the year ending December 31, 2013, we anticipate including the following disclosures in our critical accounting estimates:

“Long-lived assets are tested for recoverability whenever events or changes in circumstances indicate that the carrying amount may not be recoverable. Examples of such events or changes in circumstances related to our long-lived assets include, but are not restricted to: a significant adverse change in the extent or manner in which the asset is being used or in its physical condition; a significant adverse change in our long-term methanol price assumption or in the price or availability of natural gas feedstock required to manufacture methanol; a significant adverse change in legal factors or in the business climate that could affect the asset’s value, including an adverse action or assessment by a foreign government that impacts the use of the asset; or a current-period operating or cash flow loss combined with a history of operating or cash flow losses, or a projection or forecast that demonstrates continuing losses associated with the asset’s use.

As a consequence of the uncertain outlook for the future supply of natural gas feedstock to our Chile operations, we recorded an impairment charge at December 31, 2012 to reduce the carrying value of our Chile assets to their estimated recoverable amount. The post-impairment carrying value at December 31, 2012 of $245 million included the second methanol plant that management was considering relocating to Geismar, Louisiana. During 2013, we made a final investment decision to relocate the second facility from Chile to Geismar, Louisiana and, as a result, the $75 million carrying value of this methanol plant (adjusted for 2013 year-to-date depreciation) was removed from the Chile cash-generating unit. At December 31, 2013, our Chile cash-generating unit consists primarily of the remaining two methanol plants in Chile with a carrying value of approximately $xxx million.

As a result of insufficient natural gas feedstock during the southern hemisphere winter, we temporarily idled our Chile operations in April 2013. We restarted one methanol plant in September 2013 and have operated the plant at approximately 50% of capacity since that time supported by natural gas supplies from both Chile and Argentina. The idling of our operations and the restart were both anticipated in our December 31, 2012 recoverability test. While we continue to work with our natural gas suppliers to sustain our operations over the medium term, there is no assurance that we will be able to maintain operations through the upcoming southern hemisphere winter.

As a consequence of the continued uncertain outlook for the future supply of natural gas feedstock to our Chile operations, the carrying value of our Chile assets was tested for recoverability at December 31, 2013.

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Recoverability of long-lived assets is measured by comparing the carrying value of an asset or cash-generating unit to the estimated recoverable amount, which is the higher of its estimated fair value less costs to sell or its value in use. Value in use was determined by measuring the pre-tax cash flows expected to be generated from the cash-generating unit over its estimated useful life discounted by a pre-tax discount rate. The pre-tax discount rate used of xx% was derived from the Company’s estimated cost of capital. An impairment writedown is recorded if the carrying value exceeds the recoverable amount. An impairment writedown recognized in prior periods for an asset or cash-generating unit is reversed if there has been a subsequent recovery in the value of the asset or cash-generating unit due to changes in events and circumstances. For the purposes of recognition and measurement of an impairment writedown or reversal, we group our long-lived assets with other assets and liabilities to form a “cash-generating unit” at the lowest level for which identifiable cash flows are largely independent of the cash flows of other assets and liabilities. To the extent that our methanol facilities in a particular location are interdependent as a result of common infrastructure and/or feedstock from shared sources that can be shared within a facility location, we group our assets based on site locations for the purpose of determining impairment.

There are two key variables that impact our estimate of future cash flows from producing assets: (1) the methanol price and (2) the price and availability of natural gas feedstock. Short-term methanol price estimates are based on current supply and demand fundamentals and current methanol prices. Long-term methanol price estimates are based on our view of long-term supply and demand, and consideration is given to many factors, including, but not limited to, estimates of global industrial production rates, energy prices, changes in general economic conditions, future global methanol production capacity, industry operating rates and the global industry cost structure. Our estimate of the price and availability of natural gas takes into consideration the current contracted terms, as well as factors that we believe are relevant to supply under these contracts and supplemental natural gas sources. Other assumptions included in our estimate of future cash flows include the estimated cost incurred to maintain the facilities, estimates of transportation costs and other variable costs incurred in producing methanol in each period. Changes in these assumptions will impact our estimates of future cash flows and could impact our estimates of the useful lives of property, plant and equipment. Consequently, it is possible that our future operating results could be adversely affected by further asset impairment charges or by changes in depreciation and amortization rates related to property, plant and equipment.

Based on the test performed at December 31, 2013, the estimated recoverable amount of our Chile cash-generating unit is neither less than nor substantially in excess of its $xxx million carrying value. Our estimate of the recoverable amount was based on a long term methanol price assumption that is materially consistent with our historical results. A 10% decrease in our long term methanol price assumption would result in a reduction in the estimated recoverable amount by approximately $xx million. Our estimate of the recoverable amount was also based on natural gas prices which are materially consistent with those currently being incurred in the region and our best estimate of future natural gas availability, considering current contracted terms as well as factors that we believe are relevant to supply under these contracts and supplemental natural gas sources. A 10% increase in the natural gas price would result in a reduction in the estimated recoverable amount by approximately $xx million and a 10% decrease in the natural gas availability would result in a reduction in the estimated recoverable amount by approximately $xx million.

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We believe the estimated recoverable amount of all long-lived assets except our Chile cash-generating unit substantially exceeded their carrying value at December 31, 2013.”

Methanex Corporation (the Company) acknowledges that:

• The Company 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

• The Company 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.

Sincerely,

METHANEX CORPORATION

Ian P. Cameron

Senior Vice President, Finance and Chief Financial Officer

cc: KPMG

McCarthy Tetrault LLP

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