Steven Jacobs
Senior Staff Accountant
United States Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549

Dear Mr. Jacobs,

I have received your  comment  letter  of  January 12, 2005  regarding  Westland
Development  Co.,  Inc.'s (the 'Company') June 30, 2004 10-KSB and September 30,
2004 10-Q filings. The Company has prepared  it's  responses  and  has submitted
them to our Certified  Public Accountants,  Grant  Thornton,  LLC,  for  review.
As of this  afternoon,  we are  waiting for final review by Grant Thornton's SEC
compliance  department  and  expect  to  be able to submit our responses to your
queries numbered 1 through 3 regarding  our Form 10-KSB within the next week.

In regards to item number 4:

Form 10-Q for the Quarter Ended September 30, 2004

General

   4. Please amend the filing to include the  Section 302 and 906 Certifications
      of the Sarbanes-Oxley Act in Exhibits 31 and 32, respectively of your Form
      lO-Q. Refer to Item 601 of Regulation S-B.

      As  requested, the  Company  has  amended  its  10Q  for the Quarter ended
      September 30, 2004 to include  Section 302  and  906 Certifications of the
      Sarbanes-Oxley Act in Exhibits 31 and 32.

The Company acknowledges that:
   o  The Company is responsible for the adequacy and accuracy of the disclosure
      in the filing;
   o  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
   o  the company  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.

If you have  any  other  questions or concerns please feel free to contact me at
505.831.9600.

Sincerely,

Barbara Page, Chief Executive Officer, Chief Financial Officer and Director
Westland Development Co., Inc.