[letterhead graphic omitted - "N-Viro International Corporation"]

                                                                  March 10, 2010

United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street N.E.
Washington, D.C. 20549-4631

ATTN:   Mr. Rufus Decker, Accounting Branch Officer
          and Mr. Jeffrey Gordon, Staff Accountant
Mail Stop 4631

RE:     N-Viro International Corporation
          Form 10-K for the year ended December 31, 2008
               Forms 10-Q for the periods ended March 31, 2009, June 30, 2009
          and September 30, 2009
     File No. 0-21802

Dear Mr. Decker and Mr. Gordon:

     This  letter  is  the  second and final response to your letter of comments
dated  December  14, 2009 (the "December Letter") as supplemented by your letter
dated  January  25,  2010 (the "January Letter") concerning the Annual Report on
Form  10-K  for  the  year ended December 31, 2008 (the "2008 Annual Report") of
N-Viro  International  Corporation  (the  "Company"  or  "N-Viro")  and  certain
comments  in  the December Letter directed to the Company's quarterly reports on
Forms 10-Q for the periods ended March 31, 2009, June 30, 2009 and September 30,
2009  (the  "2009 Quarterly Reports").  This letter addresses the 2009 Quarterly
Reports.

     The  item  number  below  corresponds  to  the  item number in the December
Letter. For convenience we have reproduced the text of each comment and provided
the  Company's  response  immediately  below  the  text.

FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2008
- ----------------------------------------------
Item 9A(T) - Controls and Procedures
- ------------------------------------
Evaluation of Disclosure Controls and Procedures
- ------------------------------------------------
1.     Please amend your Form 10-K for the year ended December 31, 2008 AND YOUR
SUBSEQUENT  FORMS  10-Q to state the conclusions of your principal executive and
financial officers regarding whether your disclosure controls and procedures are
effective  or  not effective. See Item 307 of Regulation S-K. Please also remove
your disclosure implying that the cost-benefit relationship of possible controls
and  procedures is part of your effectiveness assessment. While cost-benefit may
be  a  reason  a  company  has  disclosure  controls and procedures that are not
effective,  it  is  not  something  that should be considered in concluding that
disclosure  controls  and  procedures  are  effective.  (Our  emphasis.)

     REPLY:  The Company previously filed its Amendment No. 1 to its 2008 Annual
Report  with the SEC in which the Company added language stating the conclusions
of its principal executive officer and principal financial officer regarding the
effectiveness  of  its  disclosure controls and procedures. The Company also has
removed  the  disclosure implying that the cost-benefit relationship of possible



        3450 W. Central Avenue  -  Suite No. 328  -  Toledo, Ohio  43606
                     P. 419.535.6374    -   F. 419.535.7008
                                [GRAPHIC OMITTED]
                                   nviro.com



United States Securities and Exchange Commission
March 10, 2010
Page 2


controls  and  procedures is part of the Company's effectiveness assessment.  In
response  to  a comment in the January 2010 Letter, the Company also revised its
conclusion  in  Item  9A(T) to state that the disclosure controls and procedures
are  not  effective  and  discussed  the  reasons  for  that  conclusion.

     Contemporaneously with this letter the Company is also filing amendments to
its 2009 Quarterly Reports in which it has made changes to Item 4T  identical to
the  changes  in  Item  9A(T)  of  the  2008  Annual  Report  except for altered
references  to  the  relevant  calendar  quarter covered by each such amendment.

     The  Company  hereby  acknowledges  that the Company is responsible for the
adequacy  and  accuracy  of  the  disclosure in their 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.

     Please  write  or  call  the undersigned at (419) 535-6374 ext. 116, or our
counsel,  Sol  V. Slotnik, Esq., whose telephone number is set forth below, with
any  comments  the  staff may have with regard to this letter or the amendments.
Thank  you.

Sincerely yours,

N-Viro International Corporation

By: /s/  James K. McHugh
    --------------------
     James K. McHugh
     Chief Financial Officer


cc:  via e-mail Sol V. Slotnik, Esq.     T. (212) 687-1222
                         F. (212) 986-2399