**EXHIBIT 31**

 

**CERTIFICATIONS**

 

I,Nancy G. Willis, certify that:

 

1.               I havereviewed this annual report on Form 10-K of Hugoton Royalty Trust, for whichBank of America, 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 amresponsible for establishing and maintaining disclosure controls and procedures(as defined in Exchange Act Rules 13a-15(e) and 15d-15(e)) and internal controlover financial reporting (as defined in Exchange Act Rules 13a-15(f) and15d-15(f)), or for causing such controls and procedures to be established andmaintained, for the registrant and I have:

 

(a)          Designed such disclosure controls andprocedures, or caused such disclosure controls and procedures to be designedunder my supervision, to ensure that material information relating to theregistrant, 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 internal control over financialreporting, or caused such internal control over financial reporting to bedesigned under my supervision, to provide reasonable assurance regarding thereliability of financial reporting and the preparation of financial statementsfor external purposes;

 

(c)          Evaluated the effectiveness of theregistrant’s disclosure controls and procedures and presented in this report myconclusions about the effectiveness of the disclosure controls and procedures,as of the end of the period covered by this report based on such evaluation;and

 

(d)         Disclosed in this report any change in theregistrant’s internal control over financial reporting that occurred during theregistrant’s most recent fiscal quarter (the registrant’s fourth fiscal quarterin the case of an annual report) that has materially affected, or is reasonablylikely to materially affect, the registrant’s internal control over financialreporting; and

 

5.               I havedisclosed, based on my most recent evaluation of internal control overfinancial reporting, to the registrant’s auditors:

 

(a)          All significant deficiencies and materialweaknesses in the design or operation of internal control over financialreporting which are reasonably likely to adversely affect the registrant’sability to record, process, summarize and report financial information; and

 

(b)         Any fraud, whether or not material, thatinvolves management or other employees who have a significant role in theregistrant’s internal control over financial reporting.

 

In giving the certifications in paragraphs 4 and 5 above, I have reliedto the extent I consider reasonable on information provided to me by XTO EnergyInc.

 

 
| Date: March 16, 2006 | By     | /s/ NANCY G. WILLIS   |   |
|----------------------|--------|-----------------------|--------|
|                 |   | Nancy G. Willis       |
|                 |   | Vice President        |
|                 |   | Bank of America, N.A. |

 

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