Mail Stop 3561
                                                           May 31, 2018


Nicholas Campanella
Chief Financial Officer
Sun Pacific Holding Corp
215 Gordon's Corner Road, Suite 1a
Manalapan NY 07726

       Re:    Sun Pacific Holding Corp
              Form 10-K for Fiscal Year Ended December 31, 2017
              Filed April 2, 2018
              File No. 000-51935

Dear Mr. Campanella:

        We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In our comment, we may ask you to
provide us
with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Report of the Independent Registered Public Accounting Firm, page F-2

1. We note that audit report states that the independent registered public
accounting firm has
   audited Sun Pacific Power Corporation. We note from page 4 that Sun Pacific
Power
   Corporation is a subsidiary of Sun Pacific Holding Corp and that you have
five subsidiaries.
   Please amend your filing to provide an audit report and audited financial
statements for Sun
   Pacific Holding Corp, which is your reporting company.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
 Nicholas Campanella
Sun Pacific Holding Corp
May 31, 2018
Page 2

       You may contact Patrick Kuhn at (202) 551-3308 or me at (202) 551-3380
with any
questions.

                                                        Sincerely,

                                                        /s/ Lyn Shenk

                                                        Lyn Shenk
                                                        Branch Chief
                                                        Office of
Transportation and Leisure