SecProbe.io

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                                                      September 9,
2005

Mail Stop 4561

Peter Russo
111 North Branch Street
Sellersville, PA  18960

      Re:	Delta Mutual, Inc.
		Form 10-KSB for the year ended December 31, 2004
	Forms 10-QSB for the quarters ended March 31, 2005 and June
30,
2005
		File No. 000-30563

Dear Mr. Russo:

      We have reviewed your above referenced filings and have the
following comments.  We have limited our review to only your
financial statements and related disclosures and will make no
further
review of your documents.  As such, all persons who are
responsible
for the adequacy and accuracy of the disclosure are urged to be
certain that they have included all information required pursuant
to
the Securities Exchange Act of 1934.

      In our comments, we ask you to provide us information so we
may
better understand your disclosure.  Please be as detailed as
necessary in your explanation.  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.

Form 10-KSB

Balance Sheet, page F-2

1. We note that the company has capitalized $170,000 in
construction
costs.  Explain to us the nature of these costs and refer us to
the
GAAP literature that supports the capitalization of these costs.

Note 1 Description of Business and Summary of Significant
Accounting
Policies

Evaluation of Long-Lived Assets, page F-11

2. Tell us how you considered paragraph 7 of SFAS 144 in assessing
long-lived assets for impairment based on the "present value" of
the
related estimated future cash flows. Separately, explain to us
your
impairment policy for properties to be held and used and for
properties held for sale.

Note 5 Investment In Joint Ventures, pages F-18 - F-19

3. Please tell us you interest ownership in Delta-Envirotech, Inc.
and explain what effective control means as disclosed in note 5b.
Refer us to the accounting literature that you relied on for, and
explain how it supports, your consolidation of this entity.

Note 6 - Convertible Debt, pages F-19 - F-20

4. Please provide us with your calculation of the intrinsic value
of
the embedded beneficial conversion option within the convertible
debt. Also, explain to us your basis for the amortization period
of
the intrinsic value of the beneficial conversion feature. Refer to
APB 14, EITF 98-5 and EITF 00-27.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please file your cover letter on EDGAR.  Please understand that we
may have additional comments after reviewing your 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.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and

* 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.

      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 our review of your filings or
in
response to our comments on your filings.

      You may contact Yolanda Crittendon, Staff Accountant, at
(202)
551-3472 or the undersigned at (202) 551-3414 if you have
questions.

							Sincerely,

            Jorge Bonilla
      Senior Staff Accountant

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Peter Russo
Delta Mutual, Inc.
September 9, 2005
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