Kunzman & Bollinger, Inc.
ATTORNEYS-AT-LAW
5100 N. BROOKLINE, SUITE 600
OKLAHOMA CITY, OKLAHOMA 73112
Telephone (405) 942-3501
Fax (405) 942-3527
October 15, 2008
ELECTRONIC FILING
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street N.W.
Washington, DC 20549
| RE: | Registration Statement on Form S-1 for Units in Atlas Resources Public #18-2008 Program (the “Program”) |
Dear Sir or Madam:
Pursuant to the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder, enclosed for filing on behalf of the above-referenced Program is Pre-Effective Amendment No. 2 with exhibits thereto to the Registration Statement on Form S-1.
The Pre-Effective Amendment No. 2 is submitted to update or clarify certain information set forth in the following sections:
| · | the information set forth in “Compensation” has been revised to reflect a more recent mix of the areas and properties to be drilled, along with their associated lease costs, administrative overhead costs under the drilling and operating agreement and well supervision fees; |
| · | additional areas have been added to “Proposed Activities - Secondary Areas of Operations”; |
| · | the financial statements for Atlas Resources Public #18-2008(A) L.P. have been updated; |
| · | the unaudited financial statements for Atlas Resources, LLC have been updated to June 30, 2008 and revised to update the disclosure in Footnote 2 pursuant to SEC comments; |
| · | the information set forth in Appendix A - Information Regarding Currently Proposed Prospects for Atlas Resources Public #18-2008(A) L.P. has been updated; |
| · | the ability of the partnerships to hedge directly rather than acting through Atlas Energy Resources, LLC or Atlas America, LLC has been added; and |
| · | the escrow bank has been changed from National City Bank to Wells Fargo Bank, N.A. |
Also, conforming changes have been made throughout Pre-Effective Amendment No. 2.
Kunzman & Bollinger, Inc.
Securities and Exchange Commission
October 15, 2008
Page 2
Please direct any questions or comments with respect to this filing to the undersigned or Mr. Gerald A. Bollinger at (405) 942-3501.
| | Very truly yours, KUNZMAN & BOLLINGER, INC. /s/ Wallace W. Kunzman, Jr. Wallace W. Kunzman, Jr. |
Enclosures
cc: Mr. Jack Hollander
