SecProbe.io

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								August 16, 2005

Ms. Negar Towfigh
Chief Financial Officer
Micron Enviro Systems, Inc.
789 West Pender Street
Suite 1205
Vancouver, BC, Canada	V6C 1H2

	Re:	Micron Enviro Systems, Inc.
Form 10-KSB/A (amendment No. 4) for Fiscal Year Ended December 31,
2004
		Filed July 25, 2005
		Form 10-QSB/A for the Quarterly Period Ended March 31,
2005
		Filed July 22, 2005
		Response Letter Dated July 19, 2005

Dear Ms. Towfigh:

      We have reviewed your filings and response letter, dated
July
19, 2005, and have the following additional comments.  We have
limited our review of this filing to those issues we have
addressed
in our comments.  Please provide a written response to our
comments.
Please be as detailed as necessary in your explanation.  In some
of
our comments, we may ask you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

Form 10-KSB/A (amendment No. 4)

Financial Statements, page 1

Report of Independent Registered Public Accounting Firm, page 1

1. We see that you have restated your 2004 and 2003 financial
statements to correct errors that resulted in an understatement of
additional paid-in capital and an understatement of your net loss
for
each of those years.  However, your accountant`s opinion indicates
that an adjustment has been made to retained earnings as of
December
31, 2004 to correct the error.  Please ask your accountants to
revisit the language used in their opinion, in light of the
changes
that are reflected in your restated financial statements for 2004
and
2003.

Balance Sheets, page 2

2. Your additional paid-in capital and accumulated deficit amounts
for 2003 do not correspond to their restated amounts reflected in
your Statement of Stockholders` Equity (Deficit).  Please revise
your
disclosure to correct this discrepancy.

Note 2 - Summary of Significant Accounting Policies, page 6

Accounting Pronouncements - Recent, page 6

3. We see that you have revised your disclosure in response to
prior
comment 1 to reflect that you adopted SFAS 123(R) as of December
31,
2004, which had no impact on your financial statements.  However,
SFAS 123(R), while permitting early adoption, requires that the
effective adoption date be the first date in the initial period of
adoption.  Please revise your disclosure to reflect the
appropriate
adoption date.

Oil and gas Properties, page 10

4. In responding to prior comment 2, you provide a brief
explanation
of the reasons you believe your method of depreciating and
depleting
capitalized costs related to your oil and gas producing
activities,
10 percent per year for five years, and 5 percent per year over
the
following 10 years, is appropriate.  However, we do not find your
information to be sufficiently persuasive to support accounting
that
is contrary to the explicit requirements of paragraphs 30, 35 and
38
of SFAS 19.  Therefore, it appears that you should amend your
filing
to utilize the unit-of-production methodology.  However, we ask
that
you contact us regarding this matter prior to filing your
amendment.
Please submit a schedule showing your computations of DD&A, as
reflected in your financial statements, and compared with the
amounts
that would arise following the guidance in SFAS 19.

Note 4 - Related Party Transactions, page 14

5. Please revise your disclosure to explain that realized gains
from
the sale of common stock remitted back to you by your directors
and
officers in accordance with Section 16 of the Exchange Act have
been
recorded as return of capital, to correspond with the treatment
you
have reflected in your restated financial statements.

Closing Comments

       Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your responses to our comments and provides any
requested information.  Detailed letters greatly facilitate our
review.  Please understand that we may have additional comments
after
reviewing your responses to our comments.

	You may contact Donald F. Delaney, at (202) 551-3863, if you
have questions regarding comments on the financial statements and
related matters.  Please contact me at (202) 551-3686 with any
other
questions.

								Sincerely,

								Karl Hiller
								Branch Chief

Cc:	Mr. Tom Stepp, Stepp Law Group
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Ms. Negar Towfigh
Micron Enviro Systems, Inc.
August 16, 2005
Page 1

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

   DIVISION OF
CORPORATION FINANCE
MAIL STOP 7010

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