Mail Stop 6010

      December 7, 2005




Mr. Duane D. Deaner
Chief Financial Officer
Environmental Tectonics Corporation
County Line Industrial Park
Southampton, Pennsylvania 18966

	RE:	Environmental Tectonics Corporation
		Form 10-K/A for the fiscal year ended February 5, 2005
		Filed May 26, 2005
		File No. 1-10655

Dear Mr. Deaner:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
future
filings in response to these comments.  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 information so we may better understand your disclosure.
After
reviewing this information, we may  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-K/A for the period ending February 25, 2005

Management Discussion and Analysis, page 2

Liquidity and Capital Resources, page 12
1. Revise future filings to define the financial ratios and
minimum
net worth levels required in your financial covenants.  Explain
what
would happen if you were unable to obtain a waiver or an amendment
from your lender on reasonable terms and the kind of interest rate
increases that could be imposed.

Balance Sheet, page 19

2. We note on page 23 of your footnotes that all the remaining
claims
revenue may not be received during fiscal year 2006.  Please tell
us
why none of you accounts receivables are classified as non-current
assets on your balance sheet.  Explain the classification for all
periods presented.

Statement of Operations, page 20

3. We note on page 12 of your MD&A that interest expense includes
insurance proceeds for a stolen simulator.  Generally, we would
expect to see insurance proceeds for the loss of an operating
asset
to be recorded in operations.  Please tell us why the current
classification as an offset to interest expense is appropriate.
Also, explain where these proceeds are recorded in your statement
of
cash flows.

      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 response that keys your
responses to our comments and provides any requested 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.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment 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 filings;

* 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.


      You may contact Dennis Hult, Staff Accountant, at (202) 551-
3618 or me at (202) 551-3554 if you have questions regarding
comments
on the financial statements and related matters.  In this regard,
do
not hesitate to contact Martin James, Senior Assistant Chief
Accountant at (202) 551-3671.


								Sincerely,



								Angela J. Crane
								Accounting Branch Chief

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Duane D. Deaner
Environmental Tectonics Corporation
December 7, 2005
Page 3