Mail Stop 7010
	December 19, 2005



Mr. Herb Mee, Jr., President and Chief Financial Officer
The Beard Company
Enterprise Plaza, Suite 320
5600 North May Avenue
Oklahoma City, Oklahoma 73112

Re:	The Beard Company
	Form 10-K for Fiscal Year Ended December 31, 2004
	File No. 1-12396

Dear Mr. Mee:

	Thank you for the detailed analysis and additional
information
provided in response to our conference call of October 4, 2005.
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.  After
reviewing your response and related supporting documentation we
believe that the equity method of accounting is appropriate for
your
investment in Cibola.  However, we believe that the following
revisions are required.

1.	Please amend your Form 10-K for the year ended December 31,
2004
and Forms 10-Q for the three quarters in 2005 to reflect your
share
of the earnings of Cibola under the equity method on a gross
basis.
Your restated income statement should conform to the presentation
you
provided on Schedule 7-Version 1-Full "other than temporary"
impairment.  This presentation would provide "other than
temporary"
impairment of your investment to the extent your share of Cibola
earnings exceed the actual cash distribution you earned and
received
during for the period.

2.	Also your balance sheets in the above filings should be
amended
to reflect your investment in and the related note payable to
Cibola
on a gross basis versus your current net method of disclosure.

3.	Amend the above filings to expand your footnote disclosures
to
include certain items provided in your EITF 96-16 analysis such as
Cibola`s corporate governance arrangements and the comparable
economic interests and investment at risk, which support your
accounting for this investment on the equity method of accounting
versus the consolidation of Cibola.

4.	Please include the financial statements of Cibola as required
under Rule 3-09.  Also note that Rule 3-09 (b) requires only the
2004
financial statements of Cibola be audited.

      Please amend your filings and respond to these comments
within
10 business days or tell us when you will provide us with a
response.
You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cover letter with your
amendment that keys your responses to our comments.  Detailed
cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

	You may contact Bret Johnson at (202) 551-3753 or me at (202)
551-3768 if you have questions regarding our comments.


Sincerely,



John Cash
Accounting Branch Chief

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Herb Mee, Jr.
The Beard Company
December 19, 2005
Page 1


UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

         DIVISION OF
CORPORATION FINANCE