April 7, 2006


Mail Stop 4561

VIA U.S. MAIL AND FAX (617) 332-2261

Mr. John C. Popeo
Chief Financial Officer
HRPT Properties Trust
400 Centre Street
Newton, MA  02458

      Re:	HRPT Properties Trust
      Form 10-K for the year ended December 31, 2005
      Filed March 10, 2006
      File No. 001-09317

Dear Mr. Popeo:

      We have reviewed your filing and have the following
comments.
We have limited our review to only the issues addressed below and
will make no further review of your documents.  In our comments,
we
ask 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.

Form 10-K for the year ended December 31, 2005

Item 2. Properties, pages 24 - 35

1. We note your disclosure of net operating income (loss) in total
and on a comparable property basis for each type of property in
your
portfolio (e.g. office or industrial), location (i.e. central
business district or suburban) and major geographical market.  Net
rental operating income (loss) per property, other than on a
consolidated basis, is not reconcilable to a GAAP measure since
net
operating income (loss) per property is not reported.  In future
filings, please remove your disclosure of net operating income
(loss)
per property on any basis other than on a consolidated basis or
further explain to us how you currently meet, or in future filings
be
able to meet, the disclosure requirements in Item 10(e)(1)(i) of
Regulation S-K.

2. If, in response to our comment above, you are providing net
operating income (loss) by major geographical market as an
extension
of the segment information determined in conformity with SFAS 131,
please revise your disclosure in future filings to either (1)
present
the SFAS 131-required information here or (2) include a cross
reference that clearly directs readers to the SFAS 131-required
information in the footnote to the financial statements.  We also
note that your presentation of the consolidated segment measure
net
operating income (loss) is a non-GAAP financial measure since this
measure has no authoritative meaning outside of the SFAS 131-
required
reconciliation.  As such, if you plan to retain your presentation
of
consolidated net operating income (loss) please clarify and expand
your disclosure in future filings to include the disclosures
required
by Item 10(e)(1)(i) of Regulation S-K and the disclosures referred
to
in Question 8 of the SEC`s Frequently Asked Questions Regarding
the
Use of Non-GAAP Financial Measures.  You may refer to Questions
16-21
of the SEC`s Frequently Asked Questions Regarding the Use of Non-
GAAP
Financial Measures as it relates to the presentation of segment
information.

Management`s Discussion and Analysis of Financial Condition and
Results of Operations, page 38

3. Management`s Discussion and Analysis should be a discussion and
analysis of your business as seen through the eyes of those who
manage the business rather than a recitation of your financial
statements in narrative form.  In future filings, please revise to
include a more robust discussion of your results of operations
including key comparative indicators used by management, trends
and
analysis of operating performance.  For instance, you present
comparative operating performance data in Item 2 with respect to
your
major geographical markets which we understand from your
disclosure
on page F-15 is the level where your chief operating decision
maker
evaluates your operating results and makes decisions regarding
resource allocation but you provide no segment analysis of this
data
in your MD&A.  Please tell us how you will revise your disclosure
in
future filings.  Refer to Item 303 of Regulation S-K and SEC
Release
33-8350.

Report of Independent Registered Public Accounting Firm, page F-1

4. Please have your auditor revise the second paragraph of their
audit report to state that their audit was in accordance with "the
standards" rather than "auditing standards" of the PCAOB.  Refer
to
PCAOB Auditing Standard No. 1.





Note 9, Segment Information, page F-15

5. Please clarify for us and revise your disclosure in future
filings
to explain how management defines its major markets in determining
the major market operating segments versus the all other market
operating segment.  In addition, please include the disclosures
required by paragraphs 25(b) and 28(b) as it relates to your
segment
assets and capital expenditures.


*  *  *  *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings 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 a 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 filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; 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 filings or
in
response to our comments on your filings.

	You may contact Josh Forgione, at (202) 551-3431, or me, at
(202) 551-3403, if you have questions. Please respond to the
comments
included in this letter within 10 business days or tell us when
you
will provide us with a response.  Please file your response on
EDGAR.

								Sincerely,



      Steven Jacobs
      Accounting Branch Chief

Mr. John C. Popeo
HRPT Properties Trust
April 7, 2006
Page 1