Exhibit 16.1
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                       [FOLLMER RUDZEWICZ PLC LETTERHEAD]


October  19,  2004

Securities  and  Exchange  Commission
450  Fifth  Street,  N.W.
Washington,  D.C.  20549

Ladies  and  Gentlemen:

The  firm  of  Follmer  Rudzewicz PLC was previously the independent auditor for
N-Viro  International  Corporation,  and reported on the financial statements of
the Company for the fiscal year ended December 31, 2003.  On or about, August 1,
2004,  the  partners  of  Follmer  Rudzewicz  PLC joined a new limited liability
partnership  UHY LLP.  We have read the Company's statements included under Item
4  of  its  Form 8-K, dated October 19, 2004, and we agree with such statements.



/s/   Follmer  Rudzewicz  PLC
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Follmer  Rudzewicz  PLC