SecProbe.io

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      January 7, 2005

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, amendment number 1, filed 12/13/04
		File No. 333-119668

Dear Mr. Klimek:

      This is to advise you that the staff has reviewed only those
portions of the above filing that relate to the exercise into
common
stock by purchasers of warrants in this offering.  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.

Cover Page

1. We note your response to our prior comment 1.  Please revise
your
filing to register the transaction by which purchasers of
registered
warrants exercise into common stock.  We note that your
registration
statement only relates to the resale of up to 9,353,000 shares of
common stock and the resale of 2,067,443 warrants.  Revise here
and
in your sections "The Offering" and "Plan of Distribution."
Description of Securities; page 55

2. You state twice on page 55 that 1,058,169 shares of common
stock
may be issued upon the exercise of all warrants privately placed
on
February 20, 2004, but the sum of the warrants issued in each
tranche, as listed, is 1,058,167 (352,723 + 352,722 + 352,722 =
1,058,167).  Please reconcile with your statement in Item 15,
"Information Not Required in Prospectus," that each tranche
contains
352,723 warrants.

      Additionally, in "Selling Shareholders" on page 49, you
state
that this post-effective amendment covers 927,696 warrants and
927,969 shares of common stock issuable upon exercise of the
warrants.  Elsewhere in your registration statement, it states
that
927,969 warrants were issued.

      Please revise to correct these and any other share and
warrant
numbers throughout your document.

Legal Opinion; Exhibit 5.1

3. Please have counsel revise to opine on the legality of the
warrants.

4. The legality opinion must opine on the corporate laws of the
state
of incorporation.  Revise to clarify that counsel is opining on
all
applicable statutory provisions of Colorado law, including the
rules
and regulations underlying those provisions, and the applicable
judicial and regulatory determinations.

      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 Lesli
Sheppard
at (202) 942-1887 with questions.  Otherwise, you may contact me
at
(202) 942-1950.

      			Sincerely,

      			Pamela A. 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
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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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