SecProbe.io

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                                                        November 18, 2005

Mr. William Choi, Branch Chief
Securities Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549

           RE:     ABLE ENERGY, INC.
                   FORM 10-K FOR THE FISCAL YEAR ENDED JUNE 30, 2005
                   FILED SEPTEMBER 28, 2005
                   FORM 10-Q/A FOR THE QUARTERLY PERIOD ENDED SEPTEMBER 30, 2005
                   FILED OCTOBER 21, 2005
                   FILE NO. 1-15035

Dear Mr. Choi:

We have reviewed the six (6) comments that were contained in your letter to us
dated November 7, 2005 regarding the Company's Form 10-K for the fiscal year
ended June 30, 2005 and the Company's Form 10-Q/A for the quarterly period ended
September 30, 2005. Please find herein below the Company's responses to the
questions set forth in your letter.

For your convenience, we have incorporated into this response letter your
original requests and the Company's responses in italics, as follows:

FORM 10-K FOR THE FISCAL YEAR ENDED JUNE 30, 2005

MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF
OPERATION, PAGE 14

RESULTS OF OPERATIONS, PAGE 16

        1.      We note your listing of extraordinary expense items that
                negatively affected net income for the year ending June 30,
                2005. Please abstain from using the term extraordinary to
                describe these expenses since it tends to suggest that these
                expenses are infrequent and unusual in nature, as defined in APB
                30, when they are not. Also, please include a narrative that
                explains, in greater detail, why you have chosen to

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                highlight these specific expense items from fiscal year 2005 on
                this table. Furthermore, tell us why director's fees from prior
                years are being expensed in fiscal year ended June 30, 2005
                rather than in the prior periods in which they relate.

                        |X|     THE COMPANY WILL REFRAIN FROM USING THE TERM
                                EXTRAORDINARY TO DESCRIBE THESE TYPES OF
                                EXPENSES IN FUTURE FILINGS.

                        |X|     THE COSTS INCLUDED IN THE TABLE ON PAGE 16 OF
                                THE COMPANY'S FORM 10K INCLUDE COSTS RELATED TO
                                INSTANCES THAT THE COMPANY BELIEVES WILL NOT
                                HAVE ANY SIGNIFICANT FUTURE IMPACT ON THE
                                COMPANY'S OPERATIONS. THE COMPANY HAS CHOSEN TO
                                HIGHLIGHT THESE ITEMS TO PROVIDE THE READER AN
                                INDICATION AS TO WHAT IMPACT THESE ITEMS HAD ON
                                CURRENT PERIOD OPERATIONS. INCLUDED IN THIS
                                SCHEDULE ARE COSTS RELATED TO THE ACCIDENT AT
                                OUR NEWTON FACILITY TOTALING $619K, THE
                                WRITE-OFF OF COSTS RELATED TO REFINANCING OLD
                                DEBT OF $206K, PAYMENT OF $183,000 IN DIRECTORS
                                FEES ESTABLISHED IN THE CURRENT PERIOD RELATING
                                TO PRIOR SERVICES AND A NON-CASH CHARGE OF $117K
                                RELATED TO THE ISSUANCE OF IN THE MONEY STOCK
                                OPTIONS.

                        |X|     THE COMPANY ESTABLISHED DIRECTOR'S FEES DURING
                                FISCAL 2005 FOR THE PRIOR TWO FISCAL PERIODS.
                                WHEN SUCH FEES WERE ESTABLISHED IT WAS NOTED
                                THAT THE COMPANY HAD NOT ESTABLISHED FEES FOR
                                THE PRIOR TWO YEARS. IT WAS DETERMINED THAT THE
                                EXISTING BOARD MEMBERS SHOULD RECEIVE SOME
                                COMPENSATION FOR THOSE PERIODS. THEREFORE, AN
                                AMOUNT WAS ESTABLISHED BY THE BOARD DURING
                                FISCAL 2005 RELATING TO THOSE PRIOR PERIODS.
                                SINCE NO COMPENSATION HAD BEEN ESTABLISHED IN
                                THE PRIOR YEARS AND THERE WAS NO COMMITMENT TO
                                PAY FEES DURING THOSE PERIODS NO ACCRUAL WAS
                                RECORDED IN THOSE PERIODS. ACCORDINGLY, WE
                                INCLUDED AS AN EXPENSE IN THE CURRENT FISCAL
                                YEAR.

FISCAL 2005 COMPARED TO FISCAL 2004

        2.      Your presentation of the change in net loss from fiscal year
                2004 to fiscal year 2005 excluding the gain on sale of operating
                assets of Able Propane represents a non-GAAP measure subject to
                the disclosure and reconciliation requirements of Item 10(e) of
                Regulation S-IC. Please revise your disclosure to indicate the
                reasons why you believe presentation of this non-GAAP measures
                provides useful information to investors and disclose how
                management uses this non-GAAP measure.

                        |X|     OUR PRESENTATION ON PAGE 17 INCLUDES DISCUSSION
                                OF NET LOSS FOR FISCAL 2005 VS. 2004 AND DOES
                                NOT EXCLUDE THE GAIN ON SALE OF OPERATING ASSETS
                                OF ABLE PROPANE.

                        |X|     THE PRESENTATION IN THE TABLE ON PAGE 16 ENDS AT
                                NET LOSS FOR CONTINUING OPERATIONS DUE TO THE
                                FACT THAT THE GAIN ON SALE OF OPERATING ASSETS
                                OF ABLE PROPANE IS NOT MEANINGFUL TO THE CURRENT
                                OPERATIONS OF THE COMPANY.

ITEM 9A. CONTROLS AND PROCEDURES. PAGE 22

        3.      Please refer to Item 308(c) of Regulation S-K and revise your
                disclosure to indicate whether there were "any changes," not
                just "significant" changes, in your internal

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                control over financial reporting that materially affected, or
                are reasonably likely to materially affect your internal control
                over financial reporting.

                        |X|     THERE WERE NO CHANGES, SIGNIFICANT OR OTHERWISE,
                                IN OUR INTERNAL CONTROL OVER FINANCIAL REPORTING
                                THAT MATERIALLY AFFECTED, OR WERE REASONABLY
                                LIKELY TO MATERIALLY AFFECT OUR INTERNAL CONTROL
                                OVER FINANCIAL REPORTING.

                        |X|     CHANGE WILL BE INCORPORATED IN FUTURE FILINGS.

FINANCIAL STATEMENTS. PAGE 23

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM, PAGE F-L

        4.      Please amend your Form 10-K to correct the date of the opinion.
                We assume the date should read September 14, 2005, not 2004.
                Additionally, have your auditors provide a separate opinion for
                Schedule II or have them incorporate their review of the
                schedule into the financial statement opinion.

                        |X|     THE DATE OF THE OPINION SHOULD BE SEPTEMBER 14,
                                2005. SINCE THIS IS AN OBVIOUS TYPOGRAPHICAL
                                ERROR WE BELIEVE AN AMENDED FORM 10K WOULD NOT
                                BE NECESSARY.

                        |X|     IN THE FUTURE THE AUDITORS WILL INCORPORATE
                                SCHEDULE II INTO THEIR OPINION.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS, PAGE F-8

NOTE 1. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES, PAGE F-8

        5.      Please disclose the types of expenses included in your cost of
                goods sold and in your selling, general and administrative
                expense line items.

                        |X|     TYPES OF EXPENSES IN COST OF GOODS SOLD INCLUDE
                                - COST OF ALL PRODUCTS SOLD, ALL SERVICE RELATED
                                COSTS, DRIVERS SALARIES, SERVICE AND FUEL
                                DELIVERY SUBCONTRACTORS, TRUCKING AND SERVICE
                                VAN EXPENSES, RELATED PAYROLL TAXES, EMPLOYEE
                                BENEFITS AND INSURANCE COSTS AND REPAIRS AND
                                MAINTENANCE ON TRUCKS AND VANS.

                        |X|     TYPES OF EXPENSES IN SELLING, GENERAL AND
                                ADMINISTRATIVE INCLUDE - MANAGEMENT, SALES AND
                                OFFICE SALARIES, ADVERTISING, TELEPHONE AND FAX,
                                RENT, CREDIT CARD PROCESSING FEES, COMPUTER
                                RELATED EXPENSES, BAD DEBT EXPENSE, INSURANCE,
                                PAYROLL TAXES, EMPLOYEE BENEFITS, LEGAL,
                                CONSULTING AND OTHER PROFESSIONAL FEES, AUDIT
                                FEES, UTILITIES, OFFICE REPAIRS AND MAINTENANCE
                                AND OFFICE EXPENSES.

                        |X|     THE TYPES OF EXPENSES INCLUDED IN OUR COST OF
                                GOODS SOLD AND SELLING, GENERAL AND
                                ADMINISTRATIVE EXPENSE LINE ITEMS AS DESCRIBED
                                ABOVE WILL BE INCORPORATED INTO FUTURE FILINGS.

FORM 10-Q/A FOR THE QUARTERLY PERIOD ENDED SEPTEMBER 30, 2005

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FINANCIAL STATEMENTS. PAGE 1

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS, PAGE 6

NOTE 10-- CONVERTIBLE DEBENTURES, PAGE 9

        6.      Since the conversion price of $6.50 is less than the fair market
                value of your common stock at the date of issuance, we would
                expect a beneficial conversion feature to be recorded. If you do
                not believe a beneficial conversion feature should be recorded,
                either explain your position and provide the relevant accounting
                guidance to support your position, or revise your financials
                accordingly. Additionally, tell us how you accounted for the
                warrants issued with the convertible debentures. We would expect
                the warrants to be valued separately using a fair value model,
                then allocated based on relative fair values. Since it does not
                appear that you have given recognition to these warrants, please
                revise your financials accordingly. Refer to EITF 98-5 and EITF
                00-27.

                        |X|     THE COMPANY HAS FILED A SECOND AMENDED FORM
                                10Q/A WHICH ACCOUNTS FOR THE ALLOCATION OF THE
                                WARRANTS AND THE RECOGNITION OF A BENEFICIAL
                                CONVERSION FEATURE AS FOLLOWS:

                                THE COMPANY ALLOCATED THE PROCEEDS FROM THE
                                ISSUANCE OF THE CONVERTIBLE DEBENTURES AND
                                WARRANTS BASED ON THEIR RESPECTIVE FAIR VALUES
                                AND INCLUDED $900,000 IN ADDITIONAL PAID IN
                                SURPLUS RELATED TO THE WARRANTS. IN ADDITION,
                                THE CONVERSION FEATURE OF THE CONVERTIBLE
                                DEBENTURES IS CHARACTERIZED AS A "BENEFICIAL
                                CONVERSION FEATURE." PURSUANT TO EMERGING ISSUES
                                TASK FORCE ISSUE NO. 00-27, THE COMPANY HAS
                                DETERMINED THAT THE VALUE OF THE BENEFICIAL
                                CONVERSION FEATURE IS $1,600,000. ACCORDINGLY,
                                THE COMPANY HAS DISCOUNTED THE BALANCE OF THE
                                CONVERTIBLE DEBENTURE AS OF THE DATE OF ISSUANCE
                                AND INCLUDED $1,600,000 IN ADDITIONAL PAID IN
                                SURPLUS. THE BENEFICIAL CONVERSION FEATURE IS
                                AMORTIZED FROM THE DATE OF ISSUANCE TO THE
                                STATED REDEMPTION DATE OF JULY 12, 2007, OF
                                WHICH $278,533 WAS AMORTIZED TO EXPENSE DURING
                                THE THREE MONTHS ENDED SEPTEMBER 30, 2005.

In connection with responding to your comments the company acknowledges the
following:

                        |X|     The Company is responsible for the adequacy and
                                accuracy of the disclosure in the filing;

                        |X|     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

                        |X|     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.

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Please contact the undersigned or Gregory D. Frost our Chief Executive Officer
with any questions or comments on the above.

                                                Sincerely,

                                                /s/ Steven M. Vella
                                                -------------------
                                                Steven M. Vella
                                                Chief Financial Officer

cc:     Gregory D. Frost
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