July 15, 2019

Paul Durham
Chief Financial Officer
Tsakos Energy Navigation Limited
367 Syngrou Avenue
175 64 P. Faliro
Athens, Greece

       Re: Tsakos Energy Navigation Limited
           Form 20-F for the Fiscal Year Ended December 31, 2018
           Filed April 12, 2019
           File No. 001-31236

Dear Mr. Durham:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this comment, we may have additional
comments.

Form 20-F for Fiscal Year Ended December 31, 2018

Item 5. Operating and Financial Review and Prospects
Liquidity and Capital Resources, page 95

1.    Please provide a comparative analysis of material year to year changes in
net cash
      provided by operating activities for all years presented. For example,
net cash of
      operating activities in 2018 decreased by nearly $97 million, or 57%,
from 2017, but the
      analysis only discusses a relatively small change in dry docking
expenditures. Your
      analysis should quantify all factors cited and address the material
drivers underlying those
      factors. Additionally, clearly explain how actual operating cash is
impacted by them if
      not apparent. Please note that merely citing changes in working capital
items and other
      items identified in the statement of cash flows may not provide a
sufficient basis to
      understand how operating cash between comparative periods changed. Refer
to section
      III.D of Release No. 33-6835, section IV.B.1 of Release No. 33-8350 and
section 501.04
      of the staff's Codification of Financial Reporting Releases for guidance.
 Paul Durham
Tsakos Energy Navigation Limited
July 15, 2019
Page 2

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Theresa Brillant at 202-551-3307 or Doug Jones at
202-551-3309 if you
have questions regarding the comment on the financial statements and related
matters or any
other questions.



FirstName LastNamePaul Durham                             Sincerely,
Comapany NameTsakos Energy Navigation Limited
                                                          Division of
Corporation Finance
July 15, 2019 Page 2                                      Office of
Transportation and Leisure
FirstName LastName