MardiLyn Saathoff
Chief Governance Officer and
Corporate Secretary
Tel: 503.220.2410
Fax: 503.721.2451
Toll Free: 1.800.422.4012
e-mail:mys@nwnatural.com
September 18, 2008
Mr. H. Christopher Owings
Assistant Director
Division of Corporate Finance
Securities and Exchange Commission
100 F Street, N. E.
Washington, D. C. 20549
| RE: | Northwest Natural Gas Company |
| Annual Report on Form 10-K for the Year Ended December 31, 2007 |
| Filed February 29, 2008 |
| Definitive Proxy Statement on Schedule 14A |
| Filed April 14, 2008 |
| Quarterly Report on Form 10-Q for the Period Ended June 30, 2008 |
| Filed August 6, 2008 |
| File No. 1-15973 |
Dear Mr. Owings:
Pursuant to my conversation on September 17, 2008 with Ms. Ellie Bavaria, Special Counsel, I am confirming our request for, and Ms. Bavaria’s acceptance of, an extension of time to respond to your comments in the above referenced matter. As discussed, we intend to submit our response not later than October 24, 2008.
Thank you for your consideration in this matter and please feel free to call me at the above number if you have any questions.
| Very truly yours, |
| /s/ MardiLyn Saathoff |
| MardiLyn Saathoff |
| cc: | Mark S. Dodson |
| Gregg S. Kantor |
