October 31, 2019

Byron C. (Chris) Wiley
President and Manager
Wiley Area Development LLC
572 Breckenridge Way
Beavercreek, OH 45430

       Re: Wiley Area Development LLC
           Amendment No. 5 to
           Offering Statement on Form 1-A
           Filed October 25, 2019
           File No. 024-11010

Dear Mr. Wiley:

      We have reviewed your amended offering statement 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. Unless
we note
otherwise, our references to prior comments are to comments in our October 18,
2019 letter.

Amended Form 1-A filed October 25, 2019

Exhibit 1A-11, page 1

1.    We note that the consent of Clark, Schaefer, Hackett & Co. refers to
their report dated
      September 24, 2019. However, the actual date of their report is dated
September 16,
      2019. Please revise the consent to reference the correct report date.
 Byron C. (Chris) Wiley
Wiley Area Development LLC
October 31, 2019
Page 2

       You may contact Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
if you have
questions regarding comments on the financial statements and related matters.
Please contact
John Stickel at 202-551-3324 or John Dana Brown at 202-551-3859 with any other
questions.



FirstName LastNameByron C. (Chris) Wiley                 Sincerely,
Comapany NameWiley Area Development LLC
                                                         Division of
Corporation Finance
October 31, 2019 Page 2                                  Office of Finance
FirstName LastName