Please direct replies to zip code 20549-0510


April 28, 2005

via U.S. mail and facsimile

Mr. Herb Mee, Jr., Chief Financial Officer
The Beard Company
Enterprise Plaza, Suite 320
Oklahoma City, Oklahoma 73112

Re:	Form 10-K for the fiscal year ended December 31, 2004
	File No. 1-12396

Dear Mr. Mee:

We have reviewed this filing and have the following comments.  If
you
disagree with a comment, we will consider your explanation as to
why
our comment is inapplicable or a revision is unnecessary.  Please
be
as detailed as necessary in your explanation.  In some of our
comments, we may ask you to provide us with supplemental
information
so we may better understand your disclosure.  After reviewing this
information, we may or may not raise additional comments.

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.


Form 10-K for the Year Ended December 31, 2004

General

Where a comment below requests additional disclosures or other
revisions to be made, please show us in your supplemental response
what the revisions will look like.  These revisions should be
included in your future filings.

Item 7-Contractual Obligations

1.	Please consider revising your table of contractual
obligations
to include the following:

(a)	Estimated interest payments on your long term debt; and
(b)	Other long-term liabilities.

Because the table is aimed at increasing transparency of cash
flow,
we believe these payments should be included in the table.  Please
also disclose any assumptions you made to derive these amounts.

Report of Independent Registered Public Accounting Firm

2.	Have your auditors revise their report to include a conformed
signature as required by Rule 2-02(a) of Regulation S-X.

Statement of Shareholders` Equity (Deficiency)

3.	Amend your statement of shareholders` equity to include a
column
or footnote that shows the changes in the number of shares of the
securities as required by APB 12 paragraph 10.

Note 1-Summary of Significant Accounting Policies
Earnings (Loss) Per Share

4.	Please tell us why you have included the weighted average
shares
in the deferred stock compensation plan as a common stock
equivalent
in your calculation of basic EPS.  Also, please clarify whether
such
shares are outstanding at the end of the year.

Note 5-Investments and Other Assets
Investment in Cibola Corporation

5.	Please supplementally tell us what minority rights and
control
issues you considered in your determination not to consolidate
your
80% ownership interest in Cibola Corporation.  Please cite the
appropriate accounting literature that supports your conclusion.

6.	It appears that your investment in Cibola Corporation met the
20% significance test under Rule 3-09 of Regulation S-X for the
year
ended December 31, 2004, yet no separate audited financial
statements
were provided.  Please provide your significance test
calculations,
and if necessary, amend your filing to include the audited
financial
statements of this equity method investment.

Note 9 (c) - Long-term Debt

7.	You indicate that note holders are entitled to a
bonus/production payment of $1 per ton for the coal expected to be
recovered during the term of the note resulting in an effective
interest rate of 29%, please tell us how you are currently
accounting
for this bonus/ production payment.

Item 9A-Controls and Procedures

8.	We note your disclosure that management, including your Chief
Executive Officer and Chief Financial Officer, concluded that the
Company`s disclosure controls and procedures are effective to
ensure
that information required to be disclosed by the Company in
reports
it files or submits under the Securities Exchange Act of 1934 is
"recorded, processed, summarized and reported within the time
periods
specified in the Securities and Exchange Commission rules and
forms."
Revise to clarify, if true, that your officers concluded that your
disclosure controls and procedures are also effective to ensure
that
information required to be disclosed in reports that you file or
submit under the Exchange Act is accumulated and communicated to
your
management, including your Chief Executive Officer and Chief
Financial Officer, to allow timely decisions regarding required
disclosure.  See Exchange Act Rule 13a-15(e).  Alternatively, your
officers may conclude that the Company`s disclosure controls and
procedures are "effective" without defining disclosure controls
and
procedures.

Exhibit 31

9.	Revise your certifications to conform wording to the language
provided in Item 601 (31) of Regulation S-K.

	*	*	*	*

Please respond to these comments within 10 business days, or tell
us
when you will provide us with a response.  Please provide us with
a
supplemental response letter that keys your responses to our
comments
and provides any requested supplemental information.  Detailed
letters greatly facilitate our review.  Please file your
supplemental
response on EDGAR as a correspondence file.  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 a 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 their 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 filing or in response to
our comments on your filing.




If you have any questions regarding these comments, please direct
them to Bret Johnson, Staff Accountant, at (202) 824-5478 or, in
his
absence, to the undersigned at (202) 824-5373.


Sincerely,



John Cash
Accounting Branch Chief

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The Beard Company
Form 10-K
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE