Shelter Properties I Limited Partnership 55 Beattie Place, P.O. Box 1089 Greenville, South Carolina 29602 January 20, 2005 For Commission Use Only United States Securities and Exchange Commission 450 Fifth Street, N.W., Mail Stop 3-03 Washington, D.C. 20549-0303 Attention: Charito A. Mittelman, Esq. Owen Pinkerton, Esq. Division of Corporate Finance Re: Shelter Properties I Limited Partnership Schedule 14A Proxy Statement Filed December 16, 2005 by AIMCO File No. 0-13454 Ladies & Gentlemen: We have received the comment letter, dated December 29, 2005, issued by the staff of the Securities and Exchange Commission (the "Commission") with respect to the Schedule 14A Proxy Statement referenced above. Shelter Properties I Limited Partnership (the "Company") hereby acknowledges the following: o the Company is responsible for the adequacy and accuracy of the disclosure in the filings; o 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 o 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. Very truly yours, Shelter Properties I Limited Partnership By: Shelter Realty Corporation, Corporate General Partner By: /s/ Martha L. Long ------------------------------- Martha L. Long Senior Vice President