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June 29, 2023
Paul Ogorek
Chief Executive Officer
PGD Eco Solutions, Inc.
7306 Skyview Ave.
New Port Richey, Florida 34653
Re:PGD Eco Solutions, Inc.
Offering Statement on Form 1-A
Post-qualification Amendment No. 1
Filed June 21, 2023
File No. 024-11852
Dear Paul Ogorek:
            We have reviewed your amendment and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to this letter by amending your offering statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.  After reviewing any amendment to your offering statement and the information you
provide in response to these comments, we may have additional comments.
Post-qualification Amendment No. 1 to Form 1-A
General
1.Please revise the reference to "unit" within the table on the cover page of your offering
circular, consistent with disclosure elsewhere that indicates you are offering common
shares.
2.Please revise Item 4 of Form 1-A and the capitalization section of your offering circular to
reflect that you are offering 50,000,000 common shares, consistent with your disclosure
elsewhere.

 FirstName LastNamePaul Ogorek
 Comapany NamePGD Eco Solutions, Inc.
 June 29, 2023 Page 2
 FirstName LastName
Paul Ogorek
PGD Eco Solutions, Inc.
June 29, 2023
Page 2
3.Please update disclosure throughout your offering circular.  Revise disclosure in the
dilution, capitalization, management's discussion and analysis of financial condition and
results of operations, and experts section to the audited financial statements for the year
ended December 31, 2022.  Revise information contained in other sections, including the
related party transactions section, as of the most reasonably practicable date.
Item 6. Unregistered Securities Issued or Sold Within One Year, page 1
4.Please revise to provide the information required by Item 6 of Form 1-A.  In this regard,
we note that Item 6 indicates "None" were issued, yet disclosure on page 32 of your
offering circular indicates you issued shares in the second half of 2022.  Please
additionally ensure consistency in the number of shares disclosed to be outstanding,
clarifying as appropriate the number of shares sold to date in the offering.  In this regard,
we note the cover page discloses 101,605,000 common shares outstanding; pages 3 and 18
indicate 100,000,000 common shares outstanding before or as of the offering; and page 23
discloses 101,010,000 common shares outstanding as of December 31, 2022.
Exhibits
5.Please file an updated auditor consent dated within 30 days of the filing as an exhibit.
            We will consider qualifying your offering statement at your request.  If a participant in
your offering is required to clear its compensation arrangements with FINRA, please have
FINRA advise us that it has no objections to the compensation arrangements prior to
qualification.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Please contact Gregory Herbers at 202-551-8028 or Jennifer Angelini at 202-551-3047
with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing
cc:       John J. Brannelly