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                             September 1, 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. 5
                                                            Filed August 23,
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. 5 to Form 1-A

       Relationships and Related Party Transactions, page 17

   1.                                                   We note your response
to prior comment 3 and reissue it. Please revise this section to
                                                        provide the information
required by Item 13 of Part II of Form 1-A for the periods
                                                        indicated therein,
rather than as of December 31, 2021, as the section currently provides.
                                                        If you wish to
incorporate by reference information contained in your interim financial
                                                        statements filed on
Form 1-SA, please refer to guidance in General Instruction III of Form
                                                        1-A.
       Exhibits

   2.                                                   Please file an updated
auditors' consent with your next amendment, dated within 30 days
                                                        of your filing.
 Paul Ogorek
PGD Eco Solutions, Inc.
September 1, 2023
Page 2

        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 other questions.



                                                             Sincerely,
FirstName LastNamePaul Ogorek
                                                             Division of
Corporation Finance
Comapany NamePGD Eco Solutions, Inc.
                                                             Office of
Manufacturing
September 1, 2023 Page 2
cc:       John J. Brannelly
FirstName LastName