SecProbe.io

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October 29, 2004

Mail Stop 0510

via U.S. Mail and facsimile

Joseph S. Klimek
President & Chief Executive Officer
Startech Environmental Corporation
15 Old Danbury Road, Suite 203
Wilton, CT 06897-2525

Re: 	Startech Environmental Corp.
	Form S-1
		File No. 333-119668

Dear Mr. Klimek:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in response to
these comments.  If you disagree, we will consider your explanation as
to why our comment is inapplicable or a revision is unnecessary.
Please be as detailed as necessary in your explanation.  In some of
our comments, we may ask you to provide us with supplemental
information so we may better understand your disclosure.  After
reviewing this information, we may or may not raise additional
comments.

Please understand that the purpose of our review process is to assist
you in your compliance with the applicable disclosure requirements and
to enhance the overall disclosure in your filing.  We look forward to
working with you in these respects.  We welcome any questions you may
have about our comments or on any other aspect of our review.  Feel
free to call us at the telephone numbers listed at the end of this
letter.

Introduction; page 1

1. In your introduction you state that there are up to 8,765,780
shares of common stock covered by the registration statement and
1,940,000 shares issuable pursuant to warrants.  On pages six and
fifty-four, however, you state that there are 1,940,522 shares
issuable upon exercise of warrants to purchase shares of common stock.
This discrepancy also affects the aggregate number of shares
registered for resale stated on pages six and fifty-four.  Please
reconcile these statements.

Selling Security Holders; page 50

2. Please state whether any of the selling security holders, other
than Mr. Rennie, is a broker-dealer or an affiliate of a broker-
dealer.

3. In the chart on page 50, there is an extra zero in the number of
shares John Celentano will own after the offering.  Please revise.

Plan of Distribution; page 52

4. Your registration statement covers shares of common stock,
warrants, and shares of common stock issuable upon exercise of the
warrants on behalf of the selling security holders, but does not cover
the exercise of warrants by the purchasers to whom your current
security holders propose to sell.  Please revise your disclosure to
cover these purchasers.  See Securities Act   2(a)(3).

As appropriate, please amend your registration statement in response
to these comments.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover letter
with your amendment that keys your responses to our comments and
provides any requested supplemental information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may
have additional comments after reviewing your amendment and responses
to our comments.

We urge all persons who are responsible for the accuracy and adequacy
of the disclosure in the filings reviewed by the staff to be certain
that they have provided all information investors require for an
informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have
made.

	Notwithstanding our comments, in the event the company requests
acceleration of the effective date of the pending registration
statement, it should furnish a letter, at the time of such request,
acknowledging that:

?	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;

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

?	the company may not assert this action as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

	In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the Division
of Corporation Finance in connection with our review of your filing or
in response to our comments on your filing.

We will consider a written request for acceleration of the effective
date of the registration statement as a confirmation of the fact that
those requesting acceleration are aware of their respective
responsibilities under the Securities Act of 1933 and the Securities
Exchange Act of 1934 as they relate to the proposed public offering of
the securities specified in the above registration statement.  We will
act on the request and, pursuant to delegated authority, grant
acceleration of the effective date.

We direct your attention to Rules 460 and 461 regarding requesting
acceleration of a registration statement.  Please allow adequate time
after the filing of any amendment for further review before submitting
a request for acceleration.  Please provide this request at least two
business days in advance of the requested effective date.

Please contact Matt Franker at (202) 824-5495 or me at (202) 942-1950
with questions.

			Sincerely,

			Pamela Ann Long
					Assistant Director

cc:	Scott S. Rosenblum, Esq. (via facsimile 212/715-8411)
Kramer Levin Naftalis & Frankel LLP
	919 Third Avenue
	New York, NY 10022
Joseph S. Klimek
Startech Environmental Corp.
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0404

       DIVISION OF
CORPORATION FINANCE

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