**Exhibit 31**

**CERTIFICATION**

I, Mike Ulrich, asVice President and Trust Officer of JPMorgan Chase Bank, N.A., the Trustee,certify that:

1.      I havereviewed this quarterly report on Form 10-Q of Santa Fe Energy Trust, forwhich JPMorgan Chase Bank, N.A. serves as Trustee;

2.      Based onmy knowledge, this report does not contain any untrue statement of a materialfact or omit to state a material fact necessary to make the statements made, inlight of the circumstances under which such statements were made, not misleadingwith respect to the period covered by this report;

3.      Based onmy knowledge, the financial statements, and other financial informationincluded in this 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 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)) andinternal control over financial reporting (as defined in Exchange Act Rules 13a-15(f) and15d-15(f)), or for causing such procedures to be established and maintained,for the registrant and I have:

(a)    designedsuch disclosure controls and procedures, or caused such disclosure controls andprocedures to be designed under my supervision, to ensure that materialinformation relating to the registrant, including its consolidatedsubsidiaries, is made known to me by others within those entities, particularlyduring the period in which this report is being prepared;

(b)   designedsuch internal control over financial reporting, or caused such internal controlover financial reporting to be designed under my supervision, to providereasonable assurance regarding the reliability of financial reporting and thepreparation of financial statements for external purposes in accordance withgenerally accepted accounting principles;

(c)    evaluatedthe effectiveness of the Trustee’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)   disclosedin this report any change in the Trust’s internal control over financialreporting that occurred during the registrant’s most recent fiscal quarter (theregistrant’s fourth fiscal quarter in the case of an annual report) that hasmaterially affected, or is reasonably likely to materially affect, the Trust’sinternal control over financial reporting; and

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

(a)    allsignificant deficiencies and material weaknesses in the design or operation ofthe Trust’s internal control over financial reporting which are reasonablylikely to adversely affect the registrant’s ability to record, process,summarize and report financial information; and

(b)   any fraud,whether or not material, that involves any management or other employees whohave a significant role in the Trustee’s internal control over financialreporting; and

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Ingiving the foregoing certifications, I have relied to the extent I considerreasonable on information provided to me by Devon Energy ProductionCompany, L.P.
| Date: May 9, 2005 |                               |
|------------------------|------------------------------------|
|                   | /s/ MIKE ULRICH                    |
|                   | Mike Ulrich                        |
|                   | *Vice President and Trust Officer* |

 

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