NGP CAPITAL RESOURCES COMPANY
1221 McKinney Street, Suite 2975
Houston, Texas 77010
February 4, 2008
Via EDGAR Transmission and Facsimile
Securities and Exchange Commission
100 F Street, N.W.
Washington, D.C. 20549
| Re: | NGP Capital Resources Company |
| Form N-2 filed October 15, 2007, as amended December 14, 2007 |
| and January 8, 2008 |
| File No. 333-146715 |
Ladies and Gentlemen:
Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, as amended, NGP Capital Resources Company (the “Registrant”) hereby requests that the Securities and Exchange Commission (the “Commission”) take appropriate action to accelerate the effectiveness of the above-referenced Registration Statement on Form N-2 so that it becomes effective at 5:00 p.m., Eastern Time, on February 6, 2008, or as soon thereafter as practicable.
The Registrant acknowledges that:
| • | the Registrant is responsible for the accuracy and adequacy of the disclosure in the filings; |
| • | staff comments or changes to disclosure in response to staff comments in the filings reviewed by the staff do not foreclose the Commission from taking any action with respect to the filings; and |
| • | the Registrant 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. |
Securities and Exchange Commission
February 4, 2008
Page 2
Please address any questions or comments with respect to this request to our counsel, Thompson & Knight L.L.P., by contacting either Joe Dannenmaier (telephone: (214) 969-1393; facsimile: (214) 880-3135) or Wes Williams (telephone: (214) 969-1324; facsimile: (214) 999-1567).
| Very truly yours, | ||
| NGP CAPITAL RESOURCES COMPANY | ||
| By: | /s/ John H. Homier | |
| John H. Homier | ||
| President & Chief Executive Officer | ||
