Daleco Resources Corporation
17 Wilmont Mews, 5th Floor, West Chester, PA 19382 * 610.429.0181 * Fax 610.429.0818
January 23, 2012
Mr. James Giugliano
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E., Stop 4628
Washington, D.C. 20549-4628
Re: Daleco Resources Corporation
File No. 000-12214
Form 10-K for Fiscal Year Ended September 30, 2010
Filed January 13, 2011
Dear Mr. Giugliano:
The following items are in response to the comments contained in the letter dated May 24, 2011:
| 6. | Wenotefromyourresponsetoourpriorcomment11thatyoulasttestedyourmineral propertiesforimpairmentonSeptember30,2010.Pleaseprovide tousthefollowing, separatelyfor eachmineral property you evaluated forimpairment: |
| · | Show us the total futurenetcash flows for eachproperty comparedtothe bookvalue ofeachproperty atyourimpairment testingdate; | |
| · | Tellusthe specific assumptions and inputsused for each property(e.g.prices, production rates, costs,growthratesapplied to each,etc.); | |
| · | Identifythesource of, or basisusedfor, eachsignificant assumptionor input; | |
| · | Explain why youbelievethese estimatesorassumptions areappropriate foryour forecasts; and | |
| · | Reconcile the totalbook valueof allthepropertiesyoutestedtoyour financial statements and relatednotes.Pleaseprovide uswitha detailedexplanationof any capitalizedcostsforwhichyoudidnot perform an impairment test. |
Answer:Such information is not attached to this Edgar filing but will be provided by separate cover consistent with the Registrant’s request for confidential treatment. Please return the information when you have completed your review.
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Pursuant to the Commission’s Rule 83 (17 CFR 200.83), the Registrant requests confidential treatment of such information.
The Registrant acknowledges that:
| · | the Registrant is responsible for the adequacy and accuracy of the disclosure in the filing; |
| · | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| · | the Registrant 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. |
Sincerely,
| /s/ Richard W. Blackstone | |
| Richard W. Blackstone, Vice President and | |
| Chief Accounting Officer |
| cc: | Gary J. Novinskie, Interim Chief Executive Officer, President and | |
| Chief Financial Officer | ||
| Lee Waddle, Vasquez & Company LLP | ||
| C. Warren Trainor, Ehmann, Van Denbergh & Trainor, P.C. |
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