Mail Stop 3561

								            May 30, 2006

Mr. Robert M. Plante
Vice President and Chief Financial Officer
Suburban Propane Partners, L.P.
240 Route 10 West
Whippany, NJ 07981

		RE:	Suburban Propane Partners, L.P.
			Form 10-K for Fiscal Year Ended September 24, 2005
			Filed December 5, 2005
Forms 10-Q for Fiscal Quarters Ended December 24, 2005 and March
25,
2006
			File No. 1-14222

Dear Mr. Plante:

	We have reviewed your response letter dated May 12, 2006 and
have the following additional comment.  Please be as detailed as
necessary in your explanation so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

	We welcome any questions you may have about our comment or on
any other aspect of our review.  Feel free to call us at the
telephone numbers listed at the end of this letter.


Form 10-K for Fiscal Year Ended September 24, 2005

Financial Statements, page F-1

Notes to Consolidated Financial Statements, page F-8

Note 2.  Summary of Significant Accounting Policies, page F-9

Derivative Instruments and Hedging Activities, page F-9

1. We have read your response to prior comment 3 in our letter
dated
April 28, 2006.  We do not believe that you have justified
classifying unrealized gains and losses on derivative instruments
that are not designated as hedges as operating expenses and later
reclassifying realized gains and losses to cost of products sold,
when considering paragraphs 238 and 349-350 in the Basis for
Conclusions to SFAS 133.  Furthermore, we believe that
reclassifying
realized gains and losses essentially presents hedge accounting-
like
results in the line item for cost of products sold without
applying
the strict rules of hedge accounting.  Please tell us your basis
in
GAAP for your conclusions. We would not object to revision to your
presentation on a future filings basis.

	As appropriate, please respond to this comment within 10
business days or tell us when you will provide us with a response.
Please file your response letter as a correspondence file on
EDGAR.

	You may contact Staff Accountant Ta Tanisha Henderson at
(202)
551-3322, or me at (202) 551-3843 in her absence, if you have
questions regarding comments on the financial statements and
related
matters.


		Sincerely,


		George F. Ohsiek, Jr.
	Branch Chief
Mr. Robert M. Plante
Suburban Propane Partners, L.P.
May 30, 2006
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