Mail Stop 3561

      	April 26, 2006


Gary L. Gibson
President and Chief Executive Officer
Southwestern Public Service Company
Tyler at Sixth Street
Amarillo, Texas  79101

      Re:	Southwestern Public Service Company
      Registration Statement on Form S-3
      Filed March 27, 2006
      File No. 333-132724
      Form 10-K for Fiscal Year Ended December 31, 2005
      File No. 1-03789

Dear Mr. Gibson:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
information so we may better understand your disclosure.  After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form S-3
1. Please note that it may be appropriate to include risk factors
in
your takedown supplements on issues specific to the securities,
such
as the lack of an intention to list the debt securities on any
trading market.


About This Prospectus, page 1
2. Please consider combining this section with your Our Company
section located on page 2 of your document.
3. You have indicated that a prospectus supplement "may also add,
update or change information contained in this prospectus."  A
prospectus supplement may supplement but may not contradict,
modify,
or replace information in the prospectus.  Please revise.

Description of Debt Securities, page 3
4. You have indicated that you may issue future issues of
indebtedness under an indenture other than the indenture described
in
this prospectus.  Please be advised that you must qualify your
indenture at the time of effectiveness of the registration
statement.
See Interpretations T.6 and T.8 of the Manual of Telephone
Interpretations (July 1997).  Please clarify whether you are
referring to other issues of indebtedness that will not be
registered
on this registration statement, or advise us of the basis for
issuing
other issues using an indenture or documentation other than what
you
have disclosed.

General, page 3
5. We note the disclosure that "the terms, if any, upon which the
Debt Securities will be convertible into or exchangeable for other
securities or other property of our company or another person"
will
be described in prospectus supplements that you will file.  It
does
not appear that you are eligible to issue convertible securities
based on the form eligibility requirements of Form S-3.  Please
revise.  Also, please advise us of the transaction instruction to
Form S-3 on which you will rely to issue securities.
6. In the fifth paragraph on page 5, please clarify your reference
to
"discontinued" securities.

Book-Entry System, page 9
7. Please delete the statement in the final sentence of this
section
indicating that you do not take responsibility for the accuracy of
the information you provide regarding DTC.  We would not object if
you noted that you are not responsible for the performance by DTC
of
its obligations under the rules and procedures governing its
operations.


Legal Opinions, page 12
8. Please confirm to us that you will file a legal opinion, in
either
a post-effective amendment or in a Form 8-K, for each takedown.

Exhibit 5.02
9. Counsel should remove the assumptions from the fourth paragraph
of
its opinion in which it assumes that the indenture constitutes a
valid and binding obligation under New Mexico law and that the
indenture has been duly authorized and executed and delivered by
you
in accordance with New Mexico law or the exhibit 5.01 opinion
should
directly address these matters.

Form 10-K for the Year Ended December 31, 2005

Item 1 - Business, page 3
10. Please disclose the estimated amount you spent during each of
the
last three fiscal years, for each of your segments, on research
and
development activities, if any.

Company Overview, page 5
11. In the first paragraph, you state that you derive a "major
portion" of your retail electric operating revenues from your
Texas
operations.  Please disclose this portion of your revenues that
you
derive from your Texas operations.
12. In this regard, please discuss in greater detail your business
operations regarding the generation, purchase, transmission,
distribution, and sale of electricity.  For example, please
describe
the portions of the states in which your customers are located,
and
the means in which you generate, transmit, distribute, and sell
electricity.

Utility Industry Growth, page 5
13. You state that you intend to focus on growing through
investments
in electric rate base to meet growing customer demands and to
maintain or increase reliability and quality of service to
customers.
Please discuss any investments that you are planning.

Utility Restructuring and Retail Competition, page 5
14. You state that you have no plan to implement retail
competition
in your Texas service area.  Please clarify this statement by
indicating your reasons for not implementing retail competition
and
how this will affect your business operations.  Also, in the
subsequent paragraph, you state that the retail electric business
does face some competition.  Please describe the competitive
conditions in all of the particular markets in which you compete,
estimate the number of your competitors, and estimate your
competitive position.

Pending and Recently Concluded Regulatory Proceedings, page 7
15. You discuss your regulatory proceedings with the Federal
Energy
Regulatory Commission, the Public Utility Commission of Texas, and
the New Mexico Public Regulatory Commission.  Please tell us why
you
do not discuss any proceedings with the similar commissions in
Oklahoma and Kansas, or provide disclosure regarding any
proceedings
in those states.

Capacity and Demand, page 9
16. Please disclose the complainants that filed the $3 million
rate
complaint against you at the Federal Energy Regulatory Commission
in
November 2004.

Energy Sources and Related Transmission Initiatives, page 9
17. Please disclose your practices and your industry`s practices
of
meeting the rapid delivery requirements of your customers,
assuring
yourself a continuous allotment of capacity from your suppliers,
and
providing any extended payment terms to your customers.
18. In this regard, you state that you have contractual
arrangements
to purchase power from utilities and non-regulated energy
suppliers
and that you make short-term firm and non-firm purchases.  Please
tell us whether you are dependent on a small number of suppliers
for
your energy purchases.  If so, please disclose this fact and
discuss
your options and any alternatives should you be unable to purchase
energy from one or more of your major suppliers.
19. Also, you state that you have contractual arrangements with
regional transmission service providers to deliver power and
energy
to the subsidiaries` native load customers.  Again, please
disclose
if you are dependent on a small number of regional transmission
service providers.  If so, please disclose this fact and discuss
your
options and any alternatives should one or more of these
transmission
service providers become unable to fulfill their contractual
obligations to you.

Fuel Supply and Costs, page 9
20. We note that you TUCO, Inc. has 100% of your projected 2006
supplies available but that there have been supply disruptions.
Please discuss the nature of those disruptions, and discuss your
options and any alternatives should TUCO, Inc. be unable to
provide
you will all of your coal needs.
Item 1A - Risk Factors, page 12
21. Please revise your Risk Factors so do not include risks that
are
generic or contain boilerplate language that could apply to any
issuer.  We believe a discussion of risks in generic terms does
not
tell your readers how the risk may affect their investment in you.
Please revise your Risk Factors section generally to write each
risk
factor in plain English and avoid using boilerplate or generic
risk
factors.  See Rule 421(d).  As examples, please consider the
following risk factors:

* "Our profitability depends in part on our ability to recover
costs
from our customers and there may be changes in circumstances or in
the regulatory environment that impair our ability to recover
costs
from our customers."

* "Recession, grid disturbances, acts of war or terrorism could
negatively impact our business."

* "Any reductions in our credit ratings could increase our
financing
costs and the cost of maintaining certain contractual
relationships."

Further, some of your risk factor discussions do not clearly and
concisely convey the actual risk, such as the last risk factor on
page 12 and the last risk factor on page 15.  Some of your risk
factors should be separated into multiple risk factors, such as
the
last risk factor on page 14 and the second risk factor on page 15.
Also, it is not appropriate for you to discuss the steps you are
taking to mitigate or minimize the risks you discuss in this
section.
Therefore, please remove any mitigating language such as in your
last
risk factor on page 12, the first full risk factor on page 14, and
second full risk factor on page 14.  Accordingly, please
thoroughly
revise this section to more precisely articulate the risks to your
offering from each risk factor.

Increasing costs associated with our defined benefit retirement
plans..., page 14
22. Please clarify what you mean by "assuming continuation of the
current federal interest rate relief beyond 2005."

Item 7A - Quantitative and Qualitative Disclosures About Market
Risk,
page 20
23. We note in your disclosure that you conduct short-term
wholesale
and commodity-marketing activities, including the purchase and
sale
of electric capacity, energy, and other energy-related
instruments.
For these market risk sensitive instruments entered into for
trading
purposes, it appears you have not provided the disclosure required
under Item 305 of Regulation S-K using any of the three permitted
alternatives.  Therefore, please provide the appropriate
disclosure
required by Item 305 of Regulation S-K.  To the extent you believe
this disclosure is not required due to
immateriality, please quantify for us the impact of these
activities
on your financial statements for each of the periods presented.

Item 8 - Financial Statements and Supplementary Data, page 21

Statements of Income, page 22
24. We note reconciling differences between the amounts you
present
in the "Depreciation and amortization" line item in your
statements
of income on page 22 and the related line item in your statements
of
cash flows on page 23.  Please provide us with details regarding
the
nature and quantity of the items causing this reported difference.

Disclosure Controls and Procedures, page 45
25. We note your disclosure that SPS "maintains a set of
disclosure
controls and procedures designed to ensure that information
required
to be disclosed in reports that it files or submits under the
Securities Exchange Act of 1934 is recorded, processed, summarized
and reported within the time periods specified in SEC rules and
forms."  Revise to clarify, if true, that your officers concluded
that your disclosure controls and procedures are also effective to
ensure that information required to be disclosed in the reports
that
you file or submit under the Exchange Act is accumulated and
communicated to your management, including your chief executive
officer and chief financial officer, to allow timely decisions
regarding required disclosure.  See Exchange Act Rules 13a-15(e)
and
15d-15(e).

Exhibits 31.01 and 31.02
26. We note that paragraph 4.a) of your certifications refers to
the
period in which this "annual" report is being prepared.  Please
file
revised certifications that provide the exact language included in
Item 601(b)(31) of Regulation S-K and that do not refer to the
"annual" report in paragraph 4.a).


*	*	*	*	*	*


      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we
may
have additional comments after reviewing your amendment and
responses
to our comments.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities Act
of
1933 and that they have provided all information investors require
for an informed investment 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.

      Notwithstanding our comments, in the event the company
requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such
request,
acknowledging that:

* 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;

* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and

* the company 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.

      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 connection with our review of
your
filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Regina Balderas, Staff Accountant, at (202)
551-3722 or William Choi, Accounting Branch Chief, at (202) 551-
3716
if you have questions regarding comments on the financial
statements
and related matters.  Please contact John

Fieldsend, Staff Attorney, at (202) 551-3343, Ellie Quarles,
Special
Counsel, at (202) 551-3238, or me at (202) 551-3720 with any other
questions.

Sincerely,



      H. Christopher Owings
      Assistant Director


cc:	Robert J. Joseph, Esq.
	Jones Day
	Via Fax: (312) 782-8585

Gary L. Gibson
Southwestern Public Service Company
April 26, 2006
Page 1