LANG MICHENER LLP
Lawyers - Patent & Trade Mark Agents

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1500 - 1055 West Georgia Street, P.O. Box 11117
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Telephone (604) 689-9111
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                                              File Number:    57532-0018-Letters
Web site:  www.langmichener.com
Direct Line: (604) 691-6839
Direct Fax Line: (604) 893-7623
E-Mail: ddex@lmls.com


September 9, 2008


                                      FILED AS CORRESPONDENCE ON EDGAR AND FAXED


SECURITIES AND EXCHANGE COMMISSION
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C.
U.S.A., 20549-7010
MAIL STOP 6010

ATTENTION:        MR. JIM B. ROSENBERG, SENIOR ASSISTANT CHIEF ACCOUNTANT

Dear Mr. Rosenberg:

Re:
         NATURALLY ADVANCED TECHNOLOGIES INC. (THE "COMPANY")
         FORM 10-KSB FOR THE YEAR ENDED DECEMBER 31, 2007
         FILE NO. 000-50367
         RESPONSE TO SEC COMMENT LETTER DATED AUGUST 28, 2008

         We are counsel for the  above-referenced  Company and we are pleased to
respond,  on behalf of the Company,  to the comments of the reviewing staff (the
"Staff") of the Securities and Exchange  Commission  (the "SEC") as set forth in
the SEC's comment letter of August 28, 2008 in this matter (the "SEC Letter").

         As a preliminary  statement we thank both you and the  remaining  Staff
very  much for the  opportunity  of  working  with you in  connection  with this
matter.

INTERNAL CONTROL OVER FINANCIAL REPORTING

Staff Comment:

1.       WE  ACKNOWLEDGE  THE  ADDITION  OF ITEM  8A(T)  IN YOUR  AMENDED 10-KSB
AS REQUESTED. HOWEVER, YOU HAVE NOT DELETED YOUR ORIGINAL DISCLOSURE ON PAGES
45-46 UNDER THE CAPTION "INTERNAL CONTROLS AND PROCEDURES". SINCE THE DISCLOSURE




Page 2


ON PAGES 45-46 CONTRADICTS THE INFORMATION PROVIDED UNDER ITEM 8A(T), PLEASE
FURTHER AMEND THE 10-KSB TO DELETE THE ORIGINAL DISCLOSURE.

Response:         WE THANK THE STAFF FOR ITS  COMMENT IN THIS  REGARD AND HEREBY
                  CONFIRM,  ON  BEHALF  OF THE  COMPANY,  THAT THE  COMPANY  HAS
                  DELETED  THE  DISCLOSURE  ON PAGES  45-46  UNDER  THE  CAPTION
                  "INTERNAL CONTROLS AND PROCEDURES".

         We hope and trust that the foregoing is now clear and  satisfactory  in
response to the Staff  comment as contained in the SEC Letter;  however,  should
the Staff have any further  questions or concerns in respect of the same, please
do not hesitate to immediately contact the writer at any time.

         On behalf of the Company we sincerely  thank and  appreciate  the SEC's
attention to and ongoing cooperation in this matter, and we remain,

Yours very truly,

"DANIEL D. DEX"


Daniel D. Dex
for LANG MICHENER LLP

ec:      The Company
ec:      Dale Matheson Carr-Hilton LaBonte
fax:     Jim Peklenk, Staff Accountant
         SEC, Division of Corporation Finance
         Fax No.: (202) 772-9217