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BacTech
Environmental Corporation

Address.
Suite 409, 37 King St.,

East
Toronto, Ontario

Canada
M5C 1E9

Phone:
(416) – 813-0303

Anuja
A Majmudar

Division
of Corporation Finance

Office
of Energy & Transportation

United
States Securities and Exchange Commission

100
F Street, N.E.

Washington,
D.C. 20549

    Re:

    BacTech
    Environmental Corporation

    Offering
    Statement on Form 1-A

    Filed:
    April 2, 2020

    Response
    Dated: June 17, 2020

    File
    No. 024-11187

    June
    19, 2020

Dear
Ms. Majmudar,

This
letter sets forth the response of BacTech Environmental Corporation, (“BCCEF” or the “Company”) to the
Staff’s comment letter dated June 17, 2020.

Offering
Statement on Form 1-A filed June 8, 2020

Risk
Factors

Because
directors, officers and affiliates currently and for
the foreseeable future will continue to control BacTech Environmental Corporation, page 12

1.
We note your revisions in response to prior comment 3. Please clarify how your directors and officers currently and for the foreseeable
future control BacTech or revise the heading to this risk factor to accurately reflect the disclosure in the risk factor.

Response:
The Company has revised the heading as follows:

“Because
directors, officers and affiliates currently and
for the foreseeable future will continue to control a significant percentage of BacTech Environmental Corporation, it may be difficult
for you to be able to elect directors or have a significant say in the policies of BacTech Environmental Corporation.”

Independent
Auditor’s Report, page F-3

2.
We note that while the audit report indicates the audit covers both 2018 and 2019, the opinion expressed only covers 2019. Please
make arrangements with your auditor to resolve this inconsistency. The opinion should cover both years to comply with paragraph
(c)(1)(ii) to Part F/S of Form 1-A.

Response:
The Company has received an updated Auditor Report covering both years 2018 and 2019.

General

3.
We note you have revised your offering circular cover page to reflect that your maximum offering amount is $1,000,000 in response
to prior comment 1. Please revise you disclosure to clarify, if true, that in no event will you offer more than 100,000,000 shares
at $0.01 per share or 33,333,333 shares at $0.03 per share. We also note your offering circular cover page and cover page table
continue to reference a minimum offering. If this refers to the minimum subscription amount, please revise accordingly. If there
is a minimum offering, please disclose on the cover page and plan of distribution section any arrangements to place the minimum
amount to be raised in escrow, or other similar arrangement and file any escrow arrangement as an exhibit, if applicable. Refer
to Item 17(8) of Part III to Form 1-A. Also, include the minimum amount to be raised in the table on the cover page and clarify
whether subscribers will have a right to the return of their funds. Refer Item 1(e) of Part II to Form 1-A.

Response:
The Company has further revised the offering circular to state that the Offering will be between $0.01 and $0.03 per share and
that there is a Minimum Subscription Amount of 1,000,000 shares.

If
you have any questions or require any additional information with respect to the above, please do not hesitate to contact me at
(416) 813-0303 or Andrew Coldicutt of the Law Office of Andrew Coldicutt at (619) 228-4970. Thank you for your attention to this
matter.

    BacTech
    Environmental Corporation

    /s/
    Ross Orr

    Name:
    Ross
    Orr

    Title:
    Chief
    Executive Officer, Director