February 2, 2010

By EDGAR Transmission

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-4628

Attention:  Douglas Brown

Re: Pacific Asia Petroleum, Inc.

Registration Statement on Form S-3

Filed December 18, 2009

File No. 333-163869

Dear Mr. Brown:

Pursuant to Rule 461 under the Securities Act of 1933, as amended (the “Securities Act”), Pacific Asia Petroleum, Inc. (the “Company”) hereby respectfully requests that the Securities and Exchange Commission (the “Commission”) accelerate the effectiveness of the above-referenced Registration Statement, as amended, and declare such Registration Statement effective at 5:00 p.m. (Eastern Time) on Wednesday, February 3, 2010, or as soon as practicable thereafter.

In connection with this request for acceleration, we acknowledge and agree that:

·   should the Commission or the staff of the Commission (the “Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

·   the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

·   the Company may not assert the Staff’s comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

*        *        *        *        *

Division of Corporation Finance

February 2, 2010

Page 2  of  2

We understand that the Staff will consider this request as confirmation by the Company of its awareness of its responsibilities under the Securities Act and the Securities Exchange Act of 1934, as amended as they relate to the proposed public offering of the securities specified in the above Registration Statement.

Please contact Scott C. Kline, Esq. of Pillsbury Winthrop Shaw Pittman LLP, our outside special securities counsel at (415) 983-1523, if you have any questions or concerns regarding this matter.

Very truly yours,

PACIFIC ASIA PETROLEUM, INC.

By: /s/ Frank Ingriselli                                                                                                

Name: Frank Ingriselli

Title: Chief Executive Officer

cc: Scott C. Kline, Esq.

Dawn M. Bernd-Schulz, Esq.

Pillsbury Winthrop Shaw Pittman LLP

2300 N Street, N.W.

Washington, D.C.  20037-1122