April 5, 2005



via facsimile and U.S. mail

Mr. Jonathan C. Nicholls
Finance Director
Hanson PLC
1 Grosvenor Place
London
SW1X 7JH
UK


	Re:	Hanson PLC
		20-F for the fiscal year ended December 31, 2004
		File No. 333-109672


Dear Mr. Nicholls:

      We have reviewed the above filing and have the following
engineering comments.  Our review has been limited to the areas
identified below.   Please provide us a response to the comments
below and include appropriate disclosure in future filings.  If
you
disagree, we will consider your explanation as to why our comment
is
inapplicable or additional disclosure 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.

20-F for the fiscal year ended December 31, 2004

General

1. A major portion of the revenues and resulting profit, generated
in
2004 for Hanson PLC, was due to the crushed rock, limestone, and
sand
& gravel operations. This 20-F filing also states that the company
has sufficient reserves for many years production.  Industry Guide
7
requires that you disclose material information concerning
production, reserves, locations and nature of your mineral
interests.
Reserves are defined as that part of a mineral deposit that can be
economically and legally extracted or produced at a profit at the
time of reserve determination. Industry Guide 7 can be reviewed on
the following Internet site:
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7.

In future filings provide a summary of the proven & probable
reserves
for each operational segment for the sand & gravel operations,
limestone quarries, clay pits, and crushed rock facilities.
Disclose
the following information in a table for all segment mine or
quarry
operations:

	Name and location of operational segment
	General map of individual operations
	Processing facilities and material types produced
	Ownership or leased status
	Annual production rates
	Proven and probable reserves
	Years of operation at current or planned capacity

Include only material that can be produced during the life of the
lease for reserves that are leased.  Also include only those
materials that have environmental permits for extraction.

Closing Comments

      As appropriate, please respond to the comment within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your responses to our comment
and
provide any necessary supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your responses 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 the company`s disclosure, they
are responsible for the accuracy and adequacy of the disclosures
they
have made.  In connection with responding to our comments, please
provide, in writing, a statement from the company acknowledging
that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* 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.

	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 our review of your filings or
in
response to our comments on your filings.

      Direct questions regarding engineering issues and related
disclosures to George K. Schuler, Mining Engineer, at (202) 824-
5527.
Direct questions relating to all other disclosure issues to the
undersigned at (202) 942-1870.  Direct all correspondence to the
following ZIP code: 20549-0405.



							Sincerely,



							H. Roger Schwall
							Assistant Director
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Mr. Jonathan C. Nicholls
Hanson PLC
April 5, 2005
Page 1



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

         DIVISION OF
CORPORATION FINANCE