**EXHIBIT31**

**CERTIFICATIONS**

I, Nancy G.Willis, certify that:

1.               I have reviewedthis annual report on Form 10-K of Hugoton Royalty Trust, for which Bank ofAmerica, N.A. acts as Trustee;

2.               Based on myknowledge, this annual report does not contain any untrue statement of amaterial fact or omit to state a material fact necessary to make the statementsmade, in light of the circumstances under which such statements were made, notmisleading with respect to the period covered by this annual report;

3.               Based on myknowledge, the financial statements, and other financial information includedin this annual report, fairly present in all material respects the financialcondition, distributable income and changes in trust corpus of the registrantas of, and for, the periods presented in this annual report;

4.               I am responsiblefor establishing and maintaining disclosure controls and procedures (as definedin Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal control overfinancial reporting (as defined in Exchange Act Rules 13a-15(f) and 15d-15(f)),or for causing such controls and procedures to be established and maintained,for the registrant and I have:

(a)          Designed such disclosurecontrols and procedures, or caused such disclosure controls and procedures to bedesigned under my supervision, to ensure that material information relating tothe registrant, including its consolidated subsidiaries, is made known to me byothers within those entities, particularly during the period in which thisreport is being prepared;

(b)         Designed such internalcontrol over financial reporting, or caused such internal control overfinancial reporting to be designed under my supervision, to provide reasonableassurance regarding the reliability of financial reporting and the preparationof financial statements for external purposes;

(c)          Evaluated theeffectiveness of the registrant’s disclosure controls and procedures andpresented in this report my conclusions about the effectiveness of thedisclosure controls and procedures, as of the end of the period covered by thisreport based on such evaluation; and

(d)         Disclosed in this reportany change in the registrant’s internal control over financial reporting thatoccurred during the registrant’s most recent fiscal quarter (the registrant’sfourth fiscal quarter in the case of an annual report) that has materiallyaffected, or is reasonably likely to materially affect, the registrant’sinternal control over financial reporting; and

5.               I have disclosed,based on my most recent evaluation of internal control over financialreporting, to the registrant’s auditors:

(a)          All significantdeficiencies and material weaknesses in the design or operation of internalcontrol over financial reporting which are reasonably likely to adverselyaffect the registrant’s ability to record, process, summarize and reportfinancial information; and

(b)         Any fraud, whether or notmaterial, that involves management or other employees who have a significantrole in the registrant’s internal control over financial reporting.

In giving thecertifications in paragraphs 4 and 5 above, I have relied to the extent Iconsider reasonable on information provided to me by XTO Energy Inc.
| Date: March 1, 2007 |   | By     |   | /s/ NANCY G. WILLIS   |
|---------------------|--------|--------|--------|-----------------------|
|                |   |   |   | Nancy G. Willis       |
|                |   |   |   | Vice President        |
|                |   |   |   | Bank of America, N.A. |

 

----