Mail Stop 6010


March 21, 2006


John A. MacFarland, Chief Executive Officer
Baldor Electric Company
5711 R. S. Boreham Jr. Street
Fort Smith, Arkansas 72908

Via U S Mail and FAX [(479) 648-5701]


Re:	Baldor Electric Company
	Form 10-K for the fiscal year ended December 31, 2005
	Forms 10-Q for 2005
	File No.  1-7284


Dear Mr. MacFarland:

	We have limited our review of your filing to those issues we
have addressed in our comments.  Where indicated, we think you
should
revise your documents in response to these comments in all future
filings with the Commission.  If you disagree, 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
information so we may better understand your disclosure.  After
reviewing this information, we may 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.




Mr. John A. MacFarland
Baldor Electric Company
March 21, 2006
Page 2


Form 10-K for fiscal year December 31, 2005

Financial Statements,  Exhibit 13

Consolidated Statements of Earnings, page 9

1. We see you report a separate line item "Profit sharing".
Please
explain to us the nature of these amounts, and tell us why they
are
reported as non-operating expenses.  We read on page 16 that the
profit sharing plan pays a benefit to most of your employees.
Please
tell us why this would not represent compensation that would be
included in operating expenses.

2. In future filings please clearly indicate whether each of the
non-
operating items represent income or expense.

Summary of Quarterly Results of Operations (unaudited), page 10

3. Since this table is not one of the primary financial statements
as
listed in the audit report, please consider moving this after the
audited footnotes in future filings.

Note C  Marketable Securities, page 17

4. We read in the first paragraph that you classify your
investments
as "available-for-sale".  However, at the end of the second
paragraph
you state you have the ability and intent to hold these
investments
until maturity, which is the defining characteristic of the "held-
to-
maturity" classification of investments.  Please clarify and tell
us
the accounting treatment for these investments under SFAS 115.




      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a response letter that keys your responses to our
comments and provides the requested information.  Confirm that you
will comply with these comments in all future filings with the
Commission.  Detailed response letters greatly facilitate our
review.
Please understand that we may have additional comments after
reviewing your responses to our comments and the requested
information.


Mr. John A. MacFarland
Baldor Electric Company
March 21, 2006
Page 3

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that the filing includes all information required under
the
Securities Exchange Act of 1934 and 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 the filing;

* 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.


      You may contact Jeanne Bennett at (202) 551-3606, or me at
(202) 551-3676, if you have questions regarding our comments.  In
our
absence you may contact Martin F. James, Senior Assistant Chief
Accountant, at (202) 551-3671.
      Sincerely,


      Brian R. Cascio
      Accounting Branch Chief
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