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PARSONS LAW FIRM

PARSONS LAW FIRM

ATTORNEYS AT LAW

SUITE
2070 SKYLINE TOWER

10900
NE 4TH STREET

BELLEVUE, WA 98004

(425)
451-8036   FAX (425) 451-8568

James B.
Parsons*
e-mail firm-info.@parsonslaw.biz
*Also admitted in Oregon and

jparsons@parsonslaw.biz
e-mail firm-info.@parsonslaw.biz
the Northern Mariana Islands

VIA FACSIMILE AND EDGAR CORRESPONDENCE

June 20, 2005

Mr. Robert Babula

Mr. Michael Moran

Division of Corporate Finance

U.S. Securities and Exchange
Commission

Washington, DC 20549

        Re: First National Power
        Corporation

        Your File No. 333-62588

        Form 10-KSB for the year
        ended December 31, 2004.

Dear Mr. Babula and Mr. Moran:

On behalf of First National Power Corporation ("First National Power"), I
have been requested to respond to the Securities and Exchange Commission ("SEC")
comment letter dated May 25, 2005, referencing First National Power's Form
10-KSB for the year ended December 31, 2004. The responses in this letter
correspondence to the comments contained in the letter of May 25, 2005.

Form 10-K for the year ended December 31, 2004

General

1. All modifications or amendments referenced below will be included in a
Form 10-KSBA when filed.

Item 1. Description of Business/Business Development

2. First National Power will amend its Form 10-KSB to provide a more
descriptive account of the transition from Capstone International, Inc. to First
National Power. Since the resignation of Mr. Mills, the Company has been acting
without a chief executive officer or president. It is actively searching for a
replacement, and hopes one will be appointed in the very near future. This
disclosure will be made in Form 10-KSBA.

Item 5. Market for Common Equity and Related Stock Holder Matters

3. The filing will be amended to give a range of high and low bid information
for the common stock for each quarter within the last two fiscal years.

4. The filing will amended to include information about approved equity
compensation arrangements and as required by item 201 (D) of Regulation SB.

Item 6. Management Discussion Analysis of Financial Condition Results of
Operations

5. The MD&A section of the 10-KSBA will state that the Company will be
required to raise financing through a combination of debt and/or equity of the
next twelve (12) months.

6. The 10-KSBA will reference the fact that there no off balance sheet
arrangements in 2004, nor are there expected to be any such arrangements in
2005.

Item 7. Financial Statements

7. The auditors have reviewed this comment, and have discussed this issue
with management. Based on that discussion, management's response is as follows:

    At the time of the loans from a related entity, Mr. Mills was a related
    party and an officer as defined by the Rule APB 26. However, between the
    times that the loans were made and the loans were forgiven, Mr. Mills both
    ceased to be an officer and ceased to be a related party through share
    ownership. Because the loans were from a related party, but the forgiveness
    was not, the auditors and management believe that the classification of the
    event was correct.

Item 8A. Disclosures, Controls and Procedures

8. The filing will be amended to furnish information required by Item 207 of
Regulation S-B.

Item 9. Directors, Executive Officers, Promoters and Control Persons;
Compliance with Section 16 (A) under the Exchange Act.

9. The information required Item 401, 405 and 406 of Regulation S-B,
including the ages of the executive officers and the fact that the financial
expert does not serve on the audit committee (the Company has not yet appointed
an audit committee -but please note that Mr. Pete Wanner, the Company's CFO, is
a chartered accountant) will be included.

Item 12. Certain Beneficial and Related Transactions

10. More detail regarding related party loans as required by Item 404 (A) of
Regulation S-B will be included.

Item 14. Principal Accountant Fees and Services.

11. Amounts paid for accounting services will be included.

Signatures.

12. As stated, the First National Power has not appointed a chief executive
officer to replace Mr. Mills.

13. The filing will be amended to indicate that there will be no reference to
other certifying officers. When such a certifying officer has been appointed by
the board of directors, a Form 8-K will be filed.

Please contact me if the SEC has further questions or comments regarding this
filing. Of course, we are aware that the SEC may also have additional comments
after it reviews the Form 10-KSBA, when filed.

Very truly yours,

PARSONS LAW FIRM

/s/ James B. Parsons

James B. Parsons

JBP:kla