MICROFIELD GROUP, INC.
                           111 SW COLUMBIA, SUITE 480
                             PORTLAND, OREGON 97201

                                                            June 1, 2006


VIA FACSIMILE AND EDGAR
-----------------------

United States Securities
and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Attention:  Errol Sanderson

            RE:    MICROFIELD GROUP, INC.

                   REGISTRATION STATEMENT ON FORM S-1
                   FILE NO. 333-131816

Ladies and Gentlemen:

        Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Act"), Microfield Group, Inc. (the
"Company") respectfully requests that the effective date of the registration
statement referred to above be accelerated so that it will become effective at
4:00 p.m., Eastern Daylight Time, on Thursday, June 1, 2006, or as soon
thereafter as possible. The Company acknowledges that: 1) should the Commission
or 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; 2) 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 3) the Company may not assert this action
as defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

                                        MICROFIELD GROUP, INC.


                                        BY:    /S/ RANDALL REED
                                               -----------------
                                        NAME:  RANDALL REED
                                        TITLE: CHIEF FINANCIAL OFFICER