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<SEC-DOCUMENT>0000000000-06-001114.txt : 20061012
<SEC-HEADER>0000000000-06-001114.hdr.sgml : 20061012
<ACCEPTANCE-DATETIME>20060109130011
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-06-001114
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20060109

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			BUENAVENTURA MINING CO INC
		CENTRAL INDEX KEY:			0001013131
		STANDARD INDUSTRIAL CLASSIFICATION:	METAL MINING [1000]
		IRS NUMBER:				000000000
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		AVE CARLOS VILLARAN 790
		CITY:			LIMA
		STATE:			R5
		ZIP:			13
		BUSINESS PHONE:		5114192536

	MAIL ADDRESS:	
		STREET 1:		AV. CARLOS VILLARAN 790
		CITY:			LIMA
		STATE:			R5
		ZIP:			13
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
								December 29, 2005



Mr. Carlos E. Galvez Pinillos
Chief Financial Officer
Buenaventura Mining Company Inc.
Carlos Villaran 790
Santa Catalina, Lima 13, Peru


	Re:	Buenaventura Mining Company Inc.
		Form 20-F for Fiscal Year Ended December 31, 2004
      Filed May 27, 2005
		File No. 001-14370


Dear Mr. Galvez Pinillos:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments. Please provide a written response to
our
comments.  Please be as detailed as necessary in your explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.










Form 20-F for the Fiscal Year Ended December 31, 2004

General

1. Please number all your pages in future filings.

Key Information

Risk Factors

Replacement of Reserves

2. We note your disclosure that to maintain your production
levels,
you must replace depleted reserves by exploiting known ore bodies
or
locating new deposits.  Please expand your discussion in your
Operating and Financial Review and Prospects disclosure to include
an
analysis of your reserve replacement measures and their effects on
your production levels.

Report of Independent Registered Public Accounting Firm, page F-1

3. We see that your accountant`s report was signed by Victor
Burga,
while your Index to the Financial Statements indicates that the
report was issued by Ernst & Young.  Please confirm whether Victor
Burga is the signatory for Ernst & Young, and send us a copy of
their
signed audit report that includes their firm name on it.

In future filings, in order to ensure transparent disclosure of a
firm`s identity and registration status, please have your
accountant
make clear on the face of their audit report the name of their
firm
that is issuing the audit report.  Refer to the March 9, 2004,
AICPA
International Practices Task Force Minutes that are available on
the
AICPA`s website at www.aicpa.org.

Notes to the Consolidated Financial Statements, page F-7

Note 34 - Disclosure about Information by Segments

4. In your disclosure pursuant to IAS 14, you concluded that your
only reportable segment is mining.  Since you report under Item 18
of
Form 20-F, explain to us in detail how you determined that your
segment reporting is consistent under U.S. GAAP, considering the
requirements of SFAS 131.  Without limitation, address each of the
criteria identified in paragraphs 10 through 15 of SFAS 131 in
your
response.

Provide a detailed listing of all of your segments and indicate
which
segments you have aggregated under the criteria set forth in
paragraph 17 of SFAS 131.  For the segments that you have
aggregated,
provide detailed information to justify that these segments have
similar economic characteristics and that the segments are similar
in
each of the following areas:

?	The nature of the products and services;
?	The nature of the production processes;
?	The type or class of customer for their products and
services;
?	The methods used to distribute their products or provide
their
services; and
?	If applicable, the nature of the regulatory environment.

Provide calculations that support the non-reporting of any
segments
that you have concluded do not meet the quantitative thresholds of
paragraph 18 of SFAS 131.

Also, refer to EITF 04-4 in your segment analysis.

Report of the Independent Registered Public Accounting Firm, page
F-
67

5. We note that your accountant`s report for your significant
unconsolidated subsidiary, Minera Yanacocha S.R.L., was signed by
Luis W. Montero (partner), without identification of the
associated
audit firm.  Tell us the audit firm and send us a copy of the
signed
audit report that includes the firm name on it.  In addition,
please
have your accountant indicate the city and country in which their
report was issued.

Engineering Comments

General

6. The word "development" has a very specific meaning under SEC`s
Industry Guide 7(a)(4), (see
http://www.sec.gov/divisions/corpfin/forms/industry.htm#secguide7)
..
It references the "development stage" when companies are engaged
in
preparing reserves for production.  For projects that do not have
any
"reserves," as defined by Guide 7, please remove the terms
"develop,"
or "development," and replace them, as needed, with the terms
"explore" or "exploration."  This includes the using of the terms
in
the Financial Statement headnotes and footnotes, see Instruction 1
to
paragraph (a), Industry Guide 7.

7. Insert a small-scale map showing the location of your mines and
exploration properties, as required by Instruction 3(B) of Rule
102
of Regulation S-K.  Note that the SEC`s EDGAR program now accepts
digital maps; so please include these in any future amendments
that
are filed on EDGAR.  It is relatively easy to include automatic
links
at the appropriate locations within the document to GIF or JPEG
files, which will allow the figures and/or diagrams to appear in
the
right location when the document is viewed on the Internet.  For
more
information, please consult the EDGAR manual, and if you need
addition assistance, please call Filer Support at 202-551-8900.

8. At various locations in your disclosure, you use the terms
"measured," "indicated," and "inferred" "mineral resource,"
"mineral
resource base," "drill indicated," and "geological resources" in
reference to quantity estimates.  Industry Guide 7 does not
recognize
or allow for the use of any of these approaches to disclosure in
SEC
documents.  However, the staff has traditionally allowed
registrants
to disclose quantity estimates for "non-reserve mineralized
material," or a "mineral deposit," by which we mean mineralization
that has been sufficiently sampled at close enough intervals to
reasonably assume continuity between samples within the area of
influence of the samples.  Such a deposit does not qualify as a
reserve, until a comprehensive evaluation based upon unit cost,
grade, recoveries, and other material factors conclude legal and
economic feasibility.

Generally, mineralized material should be reported as "in place"
grade and tonnage.  Estimates of contained metal or total ounces
in
mineralized material should not be reported, as these can be
confused
with reserves.  Note that "mineralized material" does not include:
1)
material reported as reserves, and 2) volumes and grades estimated
by
using geologic inference, which are sometimes classed as
"inferred"
or "possible" by some evaluators.

a. Remove the terms "measured," "indicated," inferred" "mineral
resource," "mineral resource base," "drill indicated," "geological
resources" and associated estimates.
b. If the quantities associated with the above terms meet the
requirements of mineralized material, disclose the estimates as
"mineralized material."
c. Please do not disclose estimates based on geologic inference,
such
as "inferred" or "possible" resources.

Business Overview

9. In various locations in this section, you disclose that you
"wholly own" projects, or "control" hectares of mineralized
ground.
For each of your exploration projects or mines, clarify who owns
the
mineral concession or provisional permits and, where appropriate,
if
you own the surface rights.  If you do not own the concession or
provisional permit, disclose your obligations for use of
concessions
or permits for your material exploration areas.

10. In the "Joint Venture Explorations" section, you disclose
proven
reserves of 18.8 million tons for your La Zanja project.  Provide
us
with an explanation of the basis for these reserves.

Yanacocha

11. Proven and probable reserves are disclosed for the Mines Conga
deposit.  Forward to our engineer as supplemental information, and
not as part of the Form 20-F filing, information that establishes
the
legal, technical and economic feasibility of the materials
designated
as reserves, as required by Section C of SEC`s Industry Guide 7.

This includes:

* Property and geologic maps,
* Description of your sampling and assaying procedures,
* Drill-hole maps showing drill intercepts,
* Representative geologic cross-sections and drill logs,
* Description and examples of your cut-off calculation procedures,
* Cutoffs used for each category of reserve and resource,
* Justifications for the drill hole spacings used at various
classification levels,
* A detailed description of your procedures for estimating
"reserves,"
* Copies of pertinent engineering and geological reports, and
feasibility studies or mine plans (including cashflow analyses),
* A detailed permitting and government approval schedule for the
project, particularly identifying the primary environmental or
construction approval(s) and your current location on that
schedule.

Provide the name and phone number for a technical person our
engineer
may call, if he has technical questions about your reserves.

12. Provide us with a description of the material provisions of
your
Yanacocha stability contracts.




The Company`s Property - Reserves

13. Revise your disclosure to indicate that under Industry Guide
7,
all reserve estimates are based on present conditions, but not
anticipated conditions.  In addition note that mineral reserve
estimates must be estimated according to the requirements of SEC`s
Industry Guide 7, not Commission Regulation S-X, Rule 4-10.

14. As footnotes or as part of your reserve tables, disclose the
following:

* The reserve incorporates losses for mine dilution and mining
recovery;
* The metallurgical recovery factor for each mine,
* All prices and currency conversion factors used to estimate your
reserves.
* Percent ownership of each mine, and clarify whether quantities
disclosed are for the entire mine or your share.

15. The provincial municipality of Celendin has enacted an
ordinance
similar to that of Cajamarca, which caused the reserves to the
Cerro
Quilish to be reclassified as mineralized material. Disclose how
this
legal issue may impact the reserve estimate for Minas Conga.
Explain
why the circumstances regarding this deposit are significantly
different from Cerro Quilish and why you would expect different
results.


Closing Comments

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* 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

* 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

	You may contact Lily Dang at (202) 551-3867 or Karl Hiller,
Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the financial statements and related matters.  You may
contact Roger Baer, Mining Engineer, at (202) 551-3705 with
questions
about engineering comments.  Please contact me at (202) 551-3740
with
any other questions.

								Sincerely,



								H. Roger Schwall
								Assistant Director
Mr. Galvez Pinillos
Buenaventura Mining Company, Inc.
December 29, 2005
Page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010


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