ATTORNEYS & COUNSELORS
112 East Pecan Street, Suite 2100                   Steven R. Jacobs
San Antonio, TX  78205                              (210) 978-7727 (Direct Dial)
(210) 978-7700, Fax  (210) 978-7790                 (210) 242-4560 (Direct Fax)
www.jw.com                                          sjacoba@jw.com

                              Jackson Walker L.L.P.


                                 April 12, 2006



United States Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549-7010
Attention:  Jill S. Davis
              Jennifer Goeken

         Re:      Abraxas Petroleum Corporation
                  Item 4.02 Form 8-K; Filed March 22, 2006; File No. 0-19118

Dear Ms. Davis and Ms. Goeken:

     Pursuant to my conversation with Jennifer Goeken this morning, on behalf of
our client, Abraxas Petroleum Corporation,  Abraxas has authorized us to confirm
that the use of the word "adequate" in our response dated April 11, 2006, to the
Staff's  comment  letter  dated March 23,  2006,  was  inadvertent.  Abraxas has
authorized us to confirm that Abraxas'  disclosure  controls were  effective and
designed  to ensure  that  material  information  relating  to  Abraxas  and its
consolidated  subsidiaries  required to be included in Abraxas' periodic filings
be made known to Abraxas' certifying officers by others within those entities as
of the end of each of the  quarters  ended  March 31,  2005,  June 30,  2005 and
September 30, 2005.

     Please  feel free to contact  the  undersigned  at (210)  978-7727 or Chris
Williford,  Abraxas'  CFO,  at  (210)  757-9860,  should  you  wish  to  request
additional information regarding this matter.


                                           Very truly yours,



                                          /s/Steven R. Jacobs

SRJ:mdw

cc:      Chris E. Williford