September 13, 2005
United States Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, NW, Stop 4-5
Washington, DC 20549
USA
ATTENTION: JILL S. DAVIS, BRANCH CHIEF
Dear Sirs and/or Mesdames:
RE: Teck Cominco Limited
Forms 40-F and 40-F/A1 for Fiscal Year Ended December 31, 2004
Filed March 31, 2005 and April 1, 2005
File No. 1-13184
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This letter is further to our discussions with staff with respect to our
response letter dated September 12, 2005, responding to the SEC comment letter
dated August 1, 2005 with respect to the above noted filing. Following
discussion, we are revising our response to comment number 1 in the original
letter. The comment and our revised response are set out below:
FORM 40-F FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004
CONSOLIDATED STATEMENTS OF CASH FLOW
1. SEC Comment
"We note in your reconciliation of net earnings to net cash provided by
operating activities that you present two subtotals of net earnings and various
charges and credits above total net cash provided by operating activities. We
note the Illustrative example in CICA 1540, and that the subtotal presented does
not include net income; rather the presentation only includes "items not
affecting cash." Support your disclosure of these subtotals under Canadian GAAP
as there does not appear to be a provision within CICA 1540 for this
presentation."
Response
We propose to prospectively amend our disclosure to conform to the
illustrative example in the CICA handbook, beginning with the third quarter
of 2005. We may separately disclose the subtotal as a NON-GAAP measure in
our MD&A, with appropriate qualifications and reconciliation.
September 13, 2005 Page 2 of 3
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CLOSING COMMENTS
We acknowledge that:
- the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
- staff comments or changes to disclosure in response to staff comments
do not foreclose the Commission from taking any action with respect to
the filings; 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.
If there are further questions in connection with the foregoing responses, you
may contact the undersigned at (604) 687-1117.
Yours truly,
John G. Taylor
Senior Vice President, Finance and Chief Financial Officer
September 13, 2005 Page 3 of 3
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APPENDIX A
2Q NEWS RELEASE
TECK COMINCO LIMITED
Notes to Consolidated Financial Statements
(Unaudited)
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4. OTHER INCOME (EXPENSE)
THREE MONTHS ENDED SIX MONTHS ENDED
JUNE 30 JUNE 30
(IN MILLIONS OF DOLLARS) 2005 2004 2005 2004
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Income from Fording Canadian Coal Trust $ 11 $ 4 $ 18 $ 5
Gain on sale of investments and assets 13 - 33 7
Interest and investment income 10 3 18 4
Insurance proceeds 5 9 21 9
Non-hedge derivative losses (4) - (15) -
Asset retirement obligation expense for closed properties (2) - (4) -
Minority interests (4) (2) (7) (3)
Foreign exchange gain (losses) (4) 2 (2) 3
Miscellaneous income (expense) (6) (4) (12) (10)
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$ 19 $ 12 $ 50 $ 15
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