October 21, 2005


Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C.  20549

         Re:      The Union Light, Heat and Power Company
                  Registration Statement on Form S-3
                  File No. 333-127311
                  Filed August 8, 2005

Ladies and Gentlemen:

The Union Light, Heat and Power Company ("ULH&P") hereby requests that the
Commission accelerate the effective date of the above Registration Statement,
as amended by Amendment No. 1 thereto filed with the Commission on this date,
so that it may become effective on October 25, 2005, at or about 1:00 p.m.
(or as soon thereafter as possible). In connection with this request, ULH&P
hereby acknowledges the following:

     o Should the Commission or the staff, acting pursuant to delegated
       authority, declare the filing effective, it does not foreclose the
       Commission from taking any action with respect to the filing;
     o The action of the Commission or the staff, acting pursuant to
       delegated authority, in declaring the filing effective, does not relieve
       ULH&P from its full responsibility for the accuracy and adequacy of the
       disclosure in the filing; and
     o ULH&P may not assert staff comments and the declaration of effectiveness
       as a defense in any proceeding initiated by the Commission or any person
       under the federal securities laws of the United States.

Thank you for your attention to this matter.

Sincerely,

The Union Light, Heat and Power Company


    /s/Wendy L. Aumiller
BY: Wendy L. Aumiller
    Vice President and Treasurer