SecProbe.io

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Steven Jacobs
Senior Staff Accountant
United States Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Dear Mr. Jacobs,

I have received your comment letter  of  January  12,  2005  regarding  Westland
Development  Co., Inc.'s (the  'Company') June 30, 2004 10-KSB and September 30,
2004 10-Q filings. I hope  that  the  additional information provided below will
assist you in your review and  adequately  address  your  concerns regarding the
disclosures made.

Form 10-KSB for the Year Ended June 30, 2004

Managements Discussion and Analysis of Financial Condition and Results of
Operations

Critical Accounting Policies

1.  We note  your  disclosure  that  allocable  subdivision  costs  (e.g.  road,
    sewer and  sidewalks)  and  community wide costs (engineering fees and other
    costs  that  benefit  the  entire community) related to your residential lot
    development are allocated to residential units based on  the  number of lots
    or acreage. Please tell us how this policy is consistent  with  paragraph 11
    of SFAS No. 67.

    Preconstruction costs such as  land  cost,  initial  engineering  and  other
    preliminary  costs  that  occur  prior  to platting are generally  allocated
    based upon  the  area  method  as  calculation of the relative fair value is
    impracticable in accordance with paragraph 11 of SFAS 67. Development  costs
    which may include  engineering,  roads, sewer, sidewalk, etc. and can not be
    reasonably  identified  to a  specific lot,  or project, are allocated based
    upon relative  sales value (where  relative  sales value can be  determined)
    or, in the event that the relative sales value can not be readily determined
    at  the  time  of  capitalization,  are  allocated using the area method, in
    accordance  with  paragraph  11  of  SFAS 67.  Historically,  the  Company's
    developments have been homogeneous in nature with nearly identical lot size,
    and  sales  price  within  any  given  project.  As such, allocation methods
    utilizing relative sales value, lot size or simple average allocation result
    in  the  same  allocation  percentages.  These  methods  have  been  applied
    consistently.

Notes to the Consolidated Financial Statements

Note A-Nature of Operations and Summary of Accounting Policies

7-Recognition of Income on Real Estate Transactions and Rentals

2. Please tell us your policy with respect to your revenue recognition for sales
   of developed lots to  homebuilders  (e.g. full  accrual method vs. percentage
   completion).  For  instance,  please  clarify  for  us  whether  you  have  a
   contractual  commitment  to  complete  any  of   the   following  development
   activities with respect to your  residential  lot sales to  homebuilders:  1)
   construction of roads providing  access to or through  the land,  2)  provide
   water and sewer  utilities  to the land or 3) construct  amenities  such as a
   clubhouse,  tennis  courts and  swimming  pool in the  future.  In such cases
   the percentage completion method is generally followed. Specifically refer to
   paragraphs 41 and 42 of SFAS 66.

   Sales  of  developed  lots  to home builders are recognized on a case by case
   basis dependent upon the transactions satisfaction of the full accrual method
   requirements.   Under New Mexico law,  conveyance may begin once a final plat
   is  filed  for  a  given  development.   Obtaining  a  plat requires that the
   developer either complete in its entirety the  infrastructure  related to the
   project or provide  financial guarantees  in the form of bonds to ensure that
   the  project  will  be  completed.  Generally, a homebuilder will contract to
   purchase a fixed number of lots in a given development. Westland's  contracts
   generally require the homebuilder to  conclude the purchase of a small number
   of contracted  lots (typically  5-10) at the time the final plat is recorded.
   Remaining lots are then scheduled in increments x # of days from 'substantial
   completion'. In this event, the Company  utilizes  the  City  of  Albuquerque
   Engineer's  Acceptance  Letter  as  the  event  that  triggers   'substantial
   completion'.  The vast  majority  of  the  Company's  sales  to  homebuilders
   occur under non recourse  cash  transactions,  subsequent to the 'substantial
   completion' of the  development and as such are recorded  utilizing  the full
   accrual  method.  During the fiscal year ended June 30, 2004  and the quarter
   ended  September  30,  2004,  the  Company had not  recognized  income on any
   lot or development that had not reached substantial completion. At the fiscal
   year end June 30, 2004 and the  quarter ended September 30, 2004, the Company
   was  not  obligated  to  any  homebuilder  under any additional  construction
   commitments  related to  any recorded  sale.  As  such, there  were  no  open
   transactions  requiring  percentage  of  completion   treatment  pursuant  to
   paragraphs 41 and 42 of SFAS 66. In October, 2005,  during  the  2nd  quarter
   2005 reporting period, the company accepted full payment of a large number of
   lots  at  the  time  of  final  plat filing in advance of its normal contract
   terms. This will be the first instance of an event requiring the reporting of
   a sale under the  percentage of completion method and will be included in the
   Company's December 31, 2005 report.

3. Please  clarify  for  us  whether  you  have any grazing or oil and gas lease
   income  associated  with  any  of  the  land  that  is  currently  undergoing
   development or is being held for development  (such as the 6,400  acres  held
   for the master planned community of The Petroglyphs)  and how you account for
   such income. Refer to paragraph 10 of SFAS No. 67.

   The company does not have any grazing  lease income associated  with any land
   to which the Company has capitalized  project costs.  Once a project is under
   construction  or  costs  related to the development of a project begins being
   capitalized,  no  further  leasing  activities  occur  which  could be offset
   against capitalized costs under paragraph 10 of SFAS 67. No land held for oil
   and gas drilling is subject to foreseeable future real estate development.

Form 10-Q for the Quarter Ended September 30, 2004

General

4. Please amend the filing to include the Section 302 and 906  Certifications of
   the Sarbanes-Oxley Act in Exhibits 31 and 32, respectively of your Form lO-Q.
   Refer to Item 601 of Regulation S-B.

   As requested, the Company has amended its 10Q for the Quarter ended September
   30, 2004 to include  Section 302 and 906 Certifications of the Sarbanes-Oxley
   Act in Exhibits 31 and 32.

Attached  please find our proposed revisions for future filings.
The revisions have been highlighted in bold italic for ease of your review.

The Company acknowledges that:
  o   The Company is responsible for the adequacy and accuracy of the disclosure
      in the filing;
  o   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
  o   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.

If you have any other  questions  or  concerns please feel free to contact me at
505.831.9600.

Sincerely,

Barbara Page, Chief Executive Officer, Chief Financial Officer and Director
Westland Development Co., Inc.

Attachment 1
Proposed Revisions to Future Filings

Form 10-KSB for the Year Ended June 30, 2004 Managements Discussion and Analysis
of Financial Condition and Results of Operations

Critical Accounting Policies:

Income  recognition  and  cost  allocation: In recent years, the Company has had
very few installment sales,  so  income  is  recognized  under  the full accrual
method (pursuant to SFAS 66 paragraph 5) (Issue 2)  when a property is sold with
financing  provided by the buyer. Some of the sales are basically raw land which
has little more than its original cost of $2.60 per acre.  Preconstruction costs
such as land cost, initial engineering  and other  preliminary  costs that occur
prior to platting are allocated based upon the area method as calculation of the
relative  fair  value is impracticable.  Development  costs  which  may  include
engineering, roads, sewer, sidewalk, etc. and  can  not be reasonably identified
to a specific lot,  or project,  are  allocated  based upon relative sales value
(where  relative  sales  value can be determined) or,  in  the  event  that  the
relative   sales   value   can   not  be  readily  determined  at  the  time  of
capitalization,  are  allocated  using  the  area  method,  in  accordance  with
paragraph 11 of SFAS 67. This policy has been consistently applied.

Note A:  Nature of Operations and Summary of Accounting Policies

    7. Recognition of Income on Real Estate Transactions and Rentals

Sales of developed lots to home builders are recognized  on a case by case basis
dependent  upon  the  transactions  satisfaction  of  the  full  accrual  method
requirements.   Under New Mexico law, conveyance  may begin once a final plat is
filed for a given development. Obtaining  a  plat  requires  that  the developer
either  complete  in  its  entirety the infrastructure related to the project or
provide financial guarantees in the form of  bonds  to  ensure  that the project
will be completed.  Generally, a  homebuilder will contract  to purchase a fixed
number of lots in a given development.  Westland's  contracts  generally require
the  homebuilder to conclude  the purchase of a small number of contracted  lots
(typically  5-10) at the time the final  plat  is  recorded. Remaining  lots are
then scheduled in increments x # of days from 'substantial  completion'. In this
event, the Company utilizes the City of Albuquerque Engineer's Acceptance Letter
as the event that triggers 'substantial completion'.  The  vast majority  of the
Company's  sales to homebuilders occur under  non  recourse  cash  transactions,
subsequent  to  the  'substantial completion' of the development and as such are
recorded utilizing the full accrual method.  At the  period ended ________,  the
Company  was  (was not)  obligated  under  additional  construction  commitments
related  to______________  (any  recorded  sale). These sales have been recorded
under  the  percentage  of  completion  method  (As  such,  there  are  no  open
transactions requiring percentage of completion treatment pursuant to paragraphs
41 and 42 of SFAS 66).

Rental income is recognized when earned under lease agreements.   Rents received
in advance are deferred until earned. Revenue from leases with escalating rental
payments  are  recognized on a straight-line  basis over the minimum lease term.
For leases with provisions for additional rental payments based on percentage of
annual sales,  contingent  rental income is recognized  when the lessee provides
an accounting which reflects the contingent rental income has been  earned under
the terms of the lease  agreements.  The company does not have any grazing lease
income  associated  with any land to which the  Company has capitalized  project
costs. Once a project is under construction or costs related to the  development
of a project begins being capitalized, no further leasing activities occur which
could be offset against capitalized costs under paragraph 10 of SFAS 67. No land
held  for  oil  and  gas drilling is subject to foreseeable  future  real estate
development.
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