September 27, 2006
VIA EDGAR
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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)
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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
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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,
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
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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