CPTCamden Property Trust

Please advise us whether you consider net operating income and same property net operating income to be key performance indicators. We may have further comment.

We do not consider net operating income and same property net operating income to be key performance indicators. They are two of many individual operating metrics used by the real estate industry to assess company performance. Accordingly, Camden provides these measurements to securities analysts and investors.

Unlike Funds From Operations as defined by the National Association of Real Estate Investment Trusts (“NAREIT”), there is no standard industry definition regarding the method of calculation of either net operating income or same property net operating income.

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As a result, neither net operating income nor same property net operating income is consistently defined or calculated by peer companies or investors. Net operating income, for example, does not take into account all aspects of the Company’s performance as net operating income does not include the impact of certain revenues and expenses such as equity in income of joint ventures, interest expense, income taxes, and general and administrative expenses.

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We note that your Geographic Diversification table on page 26 indicates that 18.4% of your real estate assets were concentrated in Washington, D.C. Metro and 9.5% of your real estate assets were concentrated in Houston, Texas.

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To the extent that you consider this geographic concentration to represent a material risk, please include a risk factor specifically addressing this risk in future Exchange Act periodic reports.

We refer you to the first risk factor on page 3 of our Form 10-K under the heading “Risks Associated with Capital Markets, Credit Markets, and Real Estate - Volatility in capital and credit markets, or other unfavorable changes in economic conditions, either nationally or regionally in one or more of the markets in which we operate, could adversely impact us.”

In this risk factor, we discuss key economic risks for (a) local conditions in the first bullet point, (b) declines in market rental rates in the third bullet point, and, (c) regional economic downturns affecting geographic markets in

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the sixth bullet point.

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We note your disclosure to the effect that your operating properties have an average age of 12 years, “calculated on the basis of investment dollars.” In future Exchange Act periodic reports, please clarify how this number is calculated.

The average age of our operating properties is based upon the average of the product of the gross capitalized cost of each property multiplied by the property’s physical age divided by gross capitalized costs. We will clarify this calculation in future Exchange Act periodic reports. Read in the reply ↗

In future Exchange Act periodic reports, with respect to any disclosure on costs incurred with respect to completed construction in lease-up, please clarify whether costs incurred include leasing costs.

With respect to our disclosure on costs incurred for completed construction in lease-up, we do not include leasing costs. Leasing costs are expensed as incurred. We will clarify leasing costs are expensed as incurred in future Exchange Act periodic reports. Read in the reply ↗

We were unable to locate the disclosures required by Item 407(d)(4) of Regulation S-K. Please revise your future Exchange Act periodic reports or proxy statements, as applicable, to include such disclosures or advise.

The establishment of a separately-designated audit committee, comprised solely of independent trust managers, is disclosed on page 4 of our recently-filed proxy statement and a further description of the Company’s Audit Committee, including the identity of each committee member, is disclosed on page 7 of our proxy.

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In future filings, we will clarify the Audit Committee has been established in accordance with Section 3(a)(58)(A) of the Exchange Act.

We acknowledge:

• 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.

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Please tell us whether the average monthly rental rate per apartment disclosed incorporates tenant concessions, such as free rent periods. If not, please discuss the impact of such measures on your rental revenues, in future Exchange Act periodic reports.

The average monthly rental rate per apartment disclosed incorporates tenant concessions calculated on a straight-line basis over the life of the lease, and we will confirm this treatment in future filings. Read in the reply ↗

You disclose your specific use of proceeds from your January 2012 at-the-market issuance but not your issuances in 2011. From page 34, we note that the at-the- market issuances in 2011 partially offset your cash used in financing activities. In future Exchange Act periodic reports, please include disclosure regarding the use of proceeds from your at-the-market issuances during the reported period.

In future filings, we confirm we will include disclosures regarding the use of proceeds from our at-the-market issuances during the reporting period. Read in the reply ↗

In future Exchange Act periodic reports, to the extent you hold material amount of land, please include a discussion of the amount of development the land could support.

For projects under construction we provide detailed information such as the number of apartment homes and estimated costs as described under the heading “Development and Lease-Up Properties” on page 24 of our 2011 Form 10-K. We have also historically disclosed the magnitude of our land holdings we expect to initiate active development within the next two years; however, after review of your comment we note we do not provide similar disclosures related to our projects we expect to be constructing during the next two years, and we will provide additional disclosures on the number of apartment

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units and estimated costs per project in future filings. For other land holdings not under active development, it is not possible to determine what amount of development could be supported as pre-development activities have not been initiated.

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We note your disclosure on page 5 and 35 that you expect increased levels of development activity in 2012. In future filings please expand your disclosure in MD&A to include additional analysis of your capital expenditures breaking them down between new development, redevelopment/renovations, and other capital expenditures (i.e. capitalized interest, capitalized payroll, etc.) by year.

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In addition please provide a narrative discussion for fluctuations from year to year and expectations for the future. The total of these capitalized expenditures should reconcile to the capitalized expenditures included in cash flow from investing activities within the consolidated statement of cash flows.

In future filings, we confirm we will expand our disclosure in the MD&A to include additional analysis of our capital expenditures, as well as providing a narrative discussion for fluctuations from year-to-year and expectations for the future. We also confirm such disclosures will reconcile to the consolidated statements of cash flows. Read in the reply ↗

You define same store communities as communities we owned and which were stabilized as of January 1, 2010. On page 22 you define stabilized as a property that reaches 90% occupancy at the beginning of a period. Please tell us how you would define a property that has previously reached 90% occupancy and then later goes below 90% occupancy and is not going through a redevelopment. We may have further comment.

A property which has previously reached 90% occupancy, and not going through a redevelopment, and later goes below 90% occupancy will remain classified as a same store property. Read in the reply ↗

We note that you have disclosed that construction and carrying costs are capitalized until the apartment homes are substantially completed. Please tell us, and disclose as part of your significant accounting policies and critical accounting policies in future filings, when the capitalization period begins and how that is determined.

We begin capitalization of the development, construction, and carrying costs when the development of the future asset is probable and activities necessary to get the underlying real estate ready for its intended use have been initiated. We confirm we will disclose this policy as part of our significant accounting policies and critical accounting policies in future filings.

We acknowledge:

• 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

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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.

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