April 14, 2005


via facsimile and U.S. mail

Mr. Thomas A. Janochoski
Chief Financial Officer
Great Northern Iron Ore Properties
W-1290 First National Bank Building
332 Minnesota Street
Saint Paul, Minnesota 55101



	Re:	Great Northern Iron Ore Properties
		Form 10-K, Filed February 25, 2005
		File No. 001-00701

Dear Mr. Janochoski:

      We have reviewed the above filing and have the following
comments.  Our review has been limited to the areas commented on
below.  We have asked you to provide us with supplemental
information
so we may better understand your disclosure.  After reviewing this
information, we may or may not 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

10-K for the year ended December 31, 2004

Business, page 2

1. You disclose that your lands contain taconite capable of
yielding
approximately 332 million tons of iron ore pellets.
Supplementally
provide:

* The basis for this estimate; and any supporting documents you
have.

* A map that indicates the location and boundaries of all of the
lands in which you hold an interest, and their relationship to the
operating mines that are currently paying royalties.

* A brief description of the mining operations that mine the land
you
obtain royalties from, including discussion of the extent that
these
mines operate off of your lands, and what percentage of the mine
production has come from your lands for the past several years.

Exhibit 13

      Critical Accounting Policies, page 4

2. We note under your Critical Accounting Policies disclosure that
tonnage extracted is agreed upon between Trust and lessee
engineers
based on various engineering methods.  Supplementally provide
documentation of this process and what is involved.

Closing Comments

      Please understand that we may have additional comments after
reviewing the supplemental materials you provide and your
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to the 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 Jennifer Goeken at (202) 824-5287, or in her
absence, Jill Davis at (202) 942-1981, if you have questions
regarding comments on the financial statements and related
matters.
You may contact Roger Baer at (202) 942-2965 if you have questions
regarding engineering comments.  Please contact me at (202) 942-
1870
with any other questions.  Direct all correspondence to the
following
ZIP code:  20549-0405.

							Sincerely,



							H. Roger Schwall
							Assistant Director


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Great Northern Iron Ore Properties
April 14, 2005
page 1




UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0405

         DIVISION OF
CORPORATION FINANCE