January 12, 2005


Mail Stop 0409

      VIA U.S. MAIL AND FAX (505) 831-4865

Barbara Page
Chief Executive Officer, Chief
 Financial Officer and Director
Westland Development Co., Inc.
401 Coors Boulevard, N.W.
Albuquerque, New Mexico 87121

Re:	Westland Development Co., Inc.
	Form 10-KSB for the year ended June 30, 2004
	Form 10-QSB for the quarter ended September 30, 2004
      File No. 0-07775

Dear Ms. Page:

      We have reviewed your above referenced filings and have the
following comments.  All persons who are responsible for the
adequacy
and accuracy of the disclosure are urged to be certain that they
have
included all information required pursuant to the Securities
Exchange
Act of 1934.

      Where indicated, we think you should revise your documents
in
response to these comments in future filings.  If you disagree, we
will consider your explanation as to why our comment is
inapplicable
or a revision is unnecessary.  Please be as detailed as necessary
in
your explanation.  In some of our comments, we may ask you to
provide
us with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.






Form 10-KSB for the Year Ended June 30, 2004

Managements Discussion and Analysis of Financial Condition and
Results of Operations

Critical Accounting Policies
1. We note your disclosure that allocable subdivision costs (e.g.
road, sewer and sidewalks) and community wide costs (engineering
fees
and other costs that benefit the entire community) related to your
residential lot development are allocated to residential units
based
on the number of lots or acreage. Please tell us how this policy
is
consistent with paragraph 11 of SFAS No. 67 .

Notes to the Consolidated Financial Statements

Note A-Nature of Operations and Summary of Accounting Policies

7-Recognition of Income on Real Estate Transactions and Rentals
2. Please tell us your policy with respect to your revenue
recognition for sales of developed lots to homebuilders (e.g. full
accrual method vs. percentage completion).  For instance, please
clarify for us whether you have a contractual commitment to
complete
any of the following development activities with respect to your
residential lot sales to homebuilders: 1) construction of roads
providing access to or through the land, 2) provide water and
sewer
utilities to the land or 3) construct amenities such as a
clubhouse,
tennis courts and swimming pool in the future. In such cases the
percentage completion method is generally followed. Specifically
refer to paragraphs 41 and 42 of SFAS 66.
3. Please clarify for us whether you have any grazing or oil and
gas
lease income associated with any of the land that is currently
undergoing development or is being held for development (such as
the
6,400 acres held for the master planned community of The
Petroglyphs)
and how you account for such income. Refer to paragraph 10 of SFAS
No. 67.

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 10-Q.  Refer to Item 601 of Regulation
S-B.







*    *    *    *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:

* the company 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 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.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your proposed revisions for
future
filings that keys your responses to our comments and provides any
requested supplemental information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your responses to our comments.











      You may contact Jay Spinella, Staff Accountant, at (202)
942-
7323 or Steven Jacobs, Senior Staff Accountant, at (202) 824-5222
if
you have questions regarding comments on the financial statements
and
related matters.



						Sincerely,



Steven	Jacobs
Senior Staff Accountant

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Westland Development Co., Inc.
January 12, 2005