RALPH E. DAVIS ASSOCIATES, INC.

                      Consultants-Petroleum and Natural Gas
                         3555 Timmons Lane - Suite 1105
                              Houston, Texas 77027
                                 (713) 622-8955


                               CONSENT OF ENGINEER

             We hereby  consent to the  reproduction  of our audit  report dated
October 19, 1999,  and to the  reference to our estimate  dated October 1, 1999,
appearing in this National Fuel Gas Company Annual Report on Form 10-K.

         We  also  consent  to  the   incorporation  by  reference  in  (i)  the
Registration  Statement  (Form S-8, No.  2-94539),  as amended,  relating to the
National Fuel Gas Company 1983 Incentive Stock Option Plan and the National Fuel
Gas  Company  1984  Stock  Plan,  and  in the  related  Prospectuses,  (ii)  the
Registration  Statements  (Form  S-8,  No.  333-03055   and No.  333-03057),  as
amended, relating to the National Fuel Gas Company Tax-Deferred Savings Plan and
the National Fuel Gas Company Tax-Deferred Savings Plan for Non-Union Employees,
respectively, and in the related Prospectuses,  (iii) the Registration Statement
(Form S-3, No. 333-03803), as amended, relating to $500,000,000 of National Fuel
Gas Company debentures and/or medium term notes and, in the related  Prospectus,
(iv) the  Registration  Statements  (Form S-3, No.  33-51881 and Form S-3D,  No.
333-51769),  as amended,  relating  to the  National  Fuel Gas Company  Dividend
Reinvestment and Stock Purchase Plan, and in the related  Prospectuses,  (v) the
Registration  Statement (Form S-3, No.  33-36868),  as amended,  relating to the
National  Fuel Gas Company  Customer  Stock  Purchase  Plan,  and in the related
Prospectus,  (vi) the  Registration  Statement  (Form  S-8,  No.  33-49693),  as
amended,  relating to the National  Fuel Gas Company 1993 Award and Option Plan,
and in the related Prospectus,  and (vii) the Registration  Statement (Form S-8,
No.  333-51595)  relating to the National Fuel Gas Company 1997 Award and Option
Plan, and in the related  Prospectus,  (viii) the  Registration  Statement (Form
S-4, No.  333-74887),  as amended,  relating to the acquisition of the assets of
Cunningham  Natural Gas, and in the related  Prospectus,  (ix) the  Registration
Statement  (Form S-3, No.  333-83497),  as amended,  relating to $625,000,000 of
National Fuel Gas Company  debentures  and/or  common stock,  and in the related
Prospectus, (x) the Registration Statement (Form S-3, No. 333-85711) relating to
National Fuel Gas Company Direct Stock Purchase and Dividend  Reinvestment Plan,
and in the related  Prospectus,  of the reproduction of our report dated October
19, 1999,  appearing in this  National  Fuel Gas Company  Annual  Report on Form
10-K.



                           RALPH E. DAVIS ASSOCIATES, INC.

                           /s/ Allen C. Barron, P. E.

                           Allen C. Barron, P.E.
                           Vice President

Houston, Texas
October 28, 1999