SecProbe.io

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                                November 1, 2005

BY EDGAR
--------

Securities and Exchange Commission
Division of Corporate Finance
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: Pamela A. Long, Assistant Director

     RE:   SUB SURFACE WASTE MANAGEMENT OF DELAWARE, INC.
           POST-EFFECTIVE AMENDMENT NO. 1 TO REGISTRATION STATEMENT ON FORM SB-2
           FILED ON OCTOBER 12, 2005
           FILE NO. 333-117994

Dear Ms. Long:

         Sub Surface Waste Management of Delaware, Inc. (the "Company"), hereby
transmits by EDGAR pursuant to Rule 101(a) of Regulation S-T, our responses to
the Commission's letter, dated October 28, 2005, in connection with the
Commission's review of the Company's Registration Statement on Form SB-2 filed
on October 12, 2004 (the "Registration Statement"). For the convenience of the
staff, each comment is repeated verbatim with the Company's response immediately
following.

GENERAL
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1. We note that the date of the financial statements included in the prior
prospectus was September 30, 2003. Therefore those financial statements became
stale on or about December 30, 2004. Please advise the staff on any use of the
prospectus subsequent to the date the financial statement became stale. If none,
please confirm supplementally in writing.

         RESPONSE: To the best of the Company's knowledge, there have not been
any sales under, or use of, the Prospectus after December 30, 2004.

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Division of Corporate Finance
Securities and Exchange Commission
November 1, 2005
Page 2

2. Since you filed the pending SB-2 registration statement amendment with the
incorrect filer form flag, we are unable to process and declare the filing
effective. Please file a Form "AW" to request that the SB-2 amendment be
withdrawn. Then refile the post-effective amendment No. 1 with a correct filer
Form Flag of "POS AM".

         RESPONSE: We have filed a Form "AW" requesting that the SB-2 amendment
be withdrawn and have re-filed the Post-Effective Amendment No. 1, reflecting
the Commission's comments, with a correct filer Form Flag of "POS AM".

EXPLANATORY NOTE
----------------

3. Since this is a post-effective amendment to a prior registration statement
and not a combination of registration statements, it does not appear to us that
Rule 429 applies. Please advise.

         RESPONSE:  We have removed the explanatory note.

SIGNATURES, PAGE II-5
---------------------

4. The amended registration statement should also be signed by the registrant's
principal accounting officer or controller whose title should be shown on the
signature page.

         RESPONSE: The registrant's principal accounting officer has signed the
registration statement.

         The foregoing responses are supplemented by our revisions to
Post-Effective Amendment No. 1 to the Registration Statement, of which a marked
copy will be filed by EDGAR.

                                     * * * *

     Pursuant to your request, the Company acknowledges that:

         o        should the Commission or the staff, acting pursuant to
                  delegated authority, declare the filing effective, it does not
                  foreclose the Commission from taking any action with respect
                  to the filing;

         o        the action of the Commission or the staff, acting pursuant to
                  delegated authority, in declaring the filing effective, does
                  not relive the company from its full responsibility for the
                  adequacy and accuracy of the disclosure in the filing; and

         o        the Company may not assert staff comments and the declaration
                  of effectiveness 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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Division of Corporate Finance
Securities and Exchange Commission
November 1, 2005
Page 3

         If you have any questions or further comments, please do not hesitate
to contact the undersigned at (310) 208-1182 or via fax at (310) 208-1154.

                                        Very truly yours,
                                        SUB SURFACE WASTE MANAGEMENT OF
                                        DELAWARE, INC.

                                        By: /s/ BRUCE BEATTIE
                                            ------------------------------------
                                            Bruce Beattie,
                                            Chief Executive Officer

cc:  Dorine H. Miller
     Mark Y. Abdou, Esq.

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