WASTE TECHNOLOGY CORPORATION
Tel:  (904)355-5558
      (800)231-9286
Fax:  (904)358-7013



April 14, 2006



Nili Shah
Accounting Branch Chief
Securities and Exchange Commission
1 Station Place, N.E., Stop 7010
Washington, D.C. 20549


Re:      Waste Technology Corp.
         Form 10-KSB for the fiscal year ended October 31, 2005 File No. 0-14443


Ladies and Gentlemen:

We are writing in response to your letter dated April 6, 2006 regarding your
review of the above referenced filing of Waste Technology Corporation (the
"Company").

Management's Discussion and Analysis, page 8.
- ---------------------------------------------

     1.  We note your current disclosure only discusses the factors that led to
         changes in sales and net income year over year. In future filings,
         please expand your MD&A to discuss the factors that contributed to any
         material changes in gross margins and operating expenses. In this
         regard we note that your margins have significantly fluctuated over the
         past several years. Furthermore, we note that you previously agreed to
         provide this disclosure in your letter dated April 9, 2003.

         Response to Comment 1.

         We note your comment and will include in future filings expanded MD&A
         explanations for factors that contribute to significant changes in
         gross margins and operating expenses. We would expect to revise our
         MD&A in future filings as follows:

         Gross margins declined from 20.9% in fiscal 2004 to 19.1% in 2005. The
         change in gross margin was the result of higher material costs,
         primarily steel, and a 30% increase in dealer sales which include
         dealer discounts. The lower gross margin in fiscal 2003 included a
         write-down of slow moving inventory of $250,000.


Note(i) Revenue Recognition, Page F-7
- -------------------------------------

     2.  We note from your disclosure on page 5 that you provide repair
         services. Please tell us and include in future filings your revenue
         recognition policy for repair services. We remind you that you
         previously agreed to provide this disclosure in your letter to us dated
         April 9, 2003.

         Response to Comment 2.




                5400 Rio Grande Avenue P.O. Box 6922 (zip 32236)
                 Jacksonville, Florida 32254 www.waste.tech.com


         We note your comment and will include in future filings our policy on
         service revenue. We would expect to supplement our disclosure in future
         filings as follows:

         The Company recognizes revenue from repair services in the period in
         which the service is provided.


Note 7 Commitments and Contingencies, Page F-10
- -----------------------------------------------

     3.  In your disclosure under legal proceedings on page 7, you disclose that
         an estimate of the potential range of loss cannot be made relating to
         the legal action filed in March 2005. Please tell us how you made this
         determination given that you know the plaintiffs are seeking damages of
         $820,000 through March 21, 2005 and an additional $91,550 per month
         from that day forward.

         If you should conclude the amount of loss or a range of losses can be
         reasonably estimated, tell us how you considered paragraph 8 of SFAS 5.

         Furthermore, in future filings, please provide the required disclosures
         of paragraphs 9 and 10 of SFAS 5 as part of your audited footnote for
         commitments and contingencies.

         Response to Comment 3.

         We determined the range of potential loss was estimated to be from $0
         to the amount of damages included in the complaint. In consultation
         with our legal counsel we were unable to determine a more definite
         amount. We stated what damages the plaintiff was seeking in the
         disclosure of our potential liability.

         As reported in our 10-QSB for the quarter ended January 31, 2006, Note
         9 Legal Proceedings, in February 2006 the court granted the Company's
         motion for summary judgement related to the breach of express warranty
         and dismissed the Company from the lawsuit. Our legal counsel believes
         that the plaintiff will appeal the Judgement of Dismissal. We will
         continue to update our filings based on the current progression of
         facts.

         Our counsel has indicated that the plaintiff's success in winning an
         appeal will be difficult. In any event, we will make our best effort to
         disclose the potential loss related to this or any other lawsuits
         appropriately.

         The Company acknowledges that it is responsible for the adequacy and
         accuracy of the disclosure of the Company's filings. We also
         acknowledge that comments or changes to disclosure in response to
         comments of the staff of the Securities and Exchange Commission do not
         foreclose the Commission from taking any action with respect to the
         Company's filing. Finally, the Company agrees that it may not assert
         staff comments as a defense in any proceeding initiated by the
         Commission or any person under Federal Securities Laws of the United
         States.


         Sincerely


         /s/ William E. Nielsen

         William E. Nielsen
         President & CEO