THE BEARD COMPANY
                          Enterprise Plaza, Suite 320
                             5600 North May Avenue
                         Oklahoma City, Oklahoma 73112
                               Fax (405) 842-9901
                                 (405) 842-2333

                                  June 15, 2005




Mr. Bret Johnson
Staff Accountant
Division of Corporation Finance
Securities and Exchange Commission
Washington, D.C. 20549-0510

                                           Re:  Form 10-K for the fiscal year
                                                ended December 31, 2004
                                                File No. 1-12396

Dear Mr. Johnson:

The  following is offered in response to your letter of June 13, 2005  regarding
the Form 10-K of The Beard Company:

SEC June 13, 2005 Comment No. 1
- -------------------------------

Note 5 - Investments and Other Assets
Investment in Cibola Corporation

As noted in our  letters to the SEC dated May 10 and June 7, 2005,  the  Company
owns 80% of the common  stock of Cibola  Corporation.  The Company is  entitled,
however,  under an  allocation  formula,  to  receive  as its share of  Cibola's
financial  income, a cash  distribution of less than 10% of the separate Federal
taxable income of Cibola during each year or portion  thereof in which Cibola is
a member of the  consolidated  Federal  income tax group of which the Company is
the parent. The preferred shareholders and the holders of 20% of the common have
elected to leave the  remaining  net income in Cibola  each year to enhance  the
ultimate  rate of return to Cibola  shareholders.  In  FY2004,  Cibola  reported
financial net income of approximately  $4,221,000;  however,  the Company's cash
distribution   under  the  agreed  allocation  formula  was  only  approximately
$290,000.  This  is  the  amount  that  the  Company  recorded  as  earnings  in
unconsolidated affiliates and as an increase in its investment in Cibola for the
year  2004.  The cash  was  distributed  in  January  of 2005 and the  Company's
investment in Cibola was reduced.  As previously noted,  there is no risk to the
Company's  shareholders  regarding  this amount  because the amount  reported as
earned  and  subsequently  distributed  is  known  by  the  time  the  financial
statements are made public information.

Please acknowledge receipt hereof by returning one copy of this letter with your
filing stamp endorsed thereon.  A stamped,  self-addressed  envelope is enclosed
for your convenience.

Sincerely,

THE BEARD COMPANY


HERB MEE, JR.
Herb Mee, Jr. President and
Chief Financial Officer

HMJr/do

cc:      Mr. Jerry A. Warren, Esq.
         c/o McAfee & Taft
         Tenth Floor
         Two Leadership Square
         Oklahoma City, OK 73102

         Mr. Michael Gibson
         c/o Cole & Reed, P.C.
         531 Couch Drive, Suite 200
         Oklahoma City, OK 73102-2251

         Mr. W. M. Beard
         Chairman of the Board
         c/o The Beard Company

         Mr. Jack A. Martine
         Chief Accounting Officer
         c/o The Beard Company