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<SEC-DOCUMENT>0000950142-06-001791.txt : 20070122
<SEC-HEADER>0000950142-06-001791.hdr.sgml : 20070122
<ACCEPTANCE-DATETIME>20060927140654
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000950142-06-001791
CONFORMED SUBMISSION TYPE:	CORRESP
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20060927

FILER:

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			PRECISION DRILLING TRUST
		CENTRAL INDEX KEY:			0001013605
		STANDARD INDUSTRIAL CLASSIFICATION:	DRILLING OIL & GAS WELLS [1381]
		IRS NUMBER:				000000000
		STATE OF INCORPORATION:			A0
		FISCAL YEAR END:			0430

	FILING VALUES:
		FORM TYPE:		CORRESP

	BUSINESS ADDRESS:	
		STREET 1:		150 - 6TH AVENUE S.W.
		STREET 2:		SUITE 4200
		CITY:			CALGARY
		STATE:			A0
		ZIP:			T2P 3Y7
		BUSINESS PHONE:		403-264-0251

	MAIL ADDRESS:	
		STREET 1:		150 - 6TH AVENUE S.W.
		STREET 2:		SUITE 4200
		CITY:			CALGARY
		STATE:			A0
		ZIP:			T2P 3Y7

	FORMER COMPANY:	
		FORMER CONFORMED NAME:	PRECISION DRILLING CORP
		DATE OF NAME CHANGE:	19960506
</SEC-HEADER>
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>


                                                September 27, 2006



VIA EDGAR
- ---------

Securities and Exchange Commission
Division of Corporate Finance
100 F Street, N.E.
Washington, D.C.  20549-7010
Attention:  Pradip Bhaumik

                           PRECISION DRILLING TRUST
              2005 Annual Report on Form 40-F (File No. 1-14534)
              --------------------------------------------------

Ladies and Gentlemen:

         Precision  Drilling  Trust, an Alberta trust  ("PRECISION"),  submits
this letter in response to comments  received  from the staff (the "STAFF") of
the  Securities  and Exchange  Commission  (the  "COMMISSION")  on the Trust's
Annual Report on Form 40-F for the year ended December 31, 2005, as filed with
the  Commission  on March 31, 2006,  in a letter from  Cecilia D. Blye,  dated
September  19,  2006,  (the  "SEPTEMBER  COMMENT  LETTER") as a follow up to a
letter  received on August 28, 2006 from Cecilia D. Blye (the "AUGUST  COMMENT
LETTER").  Certain  capitalized  terms  set forth in this  letter  are used as
defined in the 2005 Annual Report.

         Precision's responses to the Staff's comments are as follows:

GENERAL
- -------

1.   Please refer to comment 1 in our letter  dated  August 28,  2006.  Please
     advise  us  whether,  to the best of your  knowledge,  understanding,  or
     belief, any of the products, equipment, technologies or services BecField
     provided to Syria have military applications;  whether Syria has employed
     or will employ the products, equipment,  technologies, or services in any
     military  application;  and, if so, the nature and scope of the  military
     application(s) in which the products, equipment, technologies or services
     have been  employed or will be employed.  We note,  in this regard,  your
     representation  that, while in Syria, the equipment mobilized by BecField
     "generally" was within the control of BecField personnel.

         RESPONSE TO COMMENT 1

     To the best of our  knowledge,  understanding,  and  belief,  none of the
     BecField products, equipment, technologies, or services have any military
     applications.   In  addition,   again  to  the  best  of  our  knowledge,

<PAGE>
                                                                             2


     understanding,  and belief, these products, equipment,  technologies, and
     services were not used for any military  purpose in Syria;  rather,  they
     were used  solely for  drilling  oil or gas wells.  As  discussed  in our
     response  to the  August  Comment  Letter,  BecField  did  not  sell  any
     equipment  into Syria.  Rather,  equipment  was  brought  into Syria on a
     call-out or contract  basis for  specific oil or gas projects and removed
     from Syria when the projects  were  completed.  As also  discussed in our
     response to the August Comment Letter,  Precision disposed of BecField as
     part of a larger transaction in the summer of 2005, and neither Precision
     nor  any of its  subsidiaries  (direct  or  indirect)  presently  has any
     business in or with Syria.

If there are further questions in connection with the foregoing responses, you
may contact the undersigned at (403) 716-4500.

Yours truly,


/s/ Hank B. Swartout
- --------------------
Hank B. Swartout
Chairman and Chief Executive Officer
Precision Drilling Corporation, Administrator to Precision Drilling Trust


cc:  Andrew J. Foley
     Paul, Weiss, Rifkind, Wharton & Garrison LLP

</TEXT>
</DOCUMENT>
</SEC-DOCUMENT>
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