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                            June 15, 2020

       Michael Silvestrini
       Manager
       Energea Portfolio 1 LLC
       9 Cedar Lane
       Old Saybrook, CT 06475

                                                        Re: Energea Portfolio 1
LLC
                                                            Amendment No. 1 to
Offering Statement on Form 1-A
                                                            Filed June 5, 2020
                                                            File No. 024-11218

       Dear Mr. Silvestrini:

             We have reviewed your amended offering statement and have the
following
       comments. In some of our comments, we may ask you to provide us with
information so we
       may better understand your disclosure.

              Please respond to this letter by amending your offering statement
and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your offering statement and the
information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our June
2, 2020 letter.

       Amendment to the Offering Statement on Form 1-A

       Executive Summary
       Our Story , page 3

   1.                                                   You assert that "the
customer will typically save 20% - 40% on its electricity bill."
                                                        However, the appendices
to the offering statement indicate that the estimated customer
                                                        savings for your
Itaguai I Project and Palmas Project are 15% and 18.5%, and the
                                                        information is blank
for your Itaguai II Project. Please explain or reconcile these
                                                        apparent
inconsistencies.
       The Offering, page 4

   2.                                                   We note your response
to our prior comment 2 but continue to believe that you should file
 Michael Silvestrini
Energea Portfolio 1 LLC
June 15, 2020
Page 2
         the related material contracts. For example, it appears that the
revenues to be generated
         by the Palmas Project will represent the majority of the company's
revenues in
         2021. Please file as exhibits the contracts relating to this project
pursuant to Section
         6(b)(ii) of Item 17 of Form 1-A, or tell us why you believe these
contracts are not required
         to be filed.
Our First Projects, page 26

3.       You disclose an 'Estimated Project IRR" for each of your anticipated
first three projects.
         Please explain to us in necessary detail how you calculated these
internal rates of return.
         In addition, please ensure that all material assumptions underlying
these calculations are
         disclosed in the offering statement.
Financial Statements
Notes to financial statements, page F-8

4.       We note your response to prior comment 5 indicating that the company's
fiscal year ends
         on December 31st for both tax and financial reporting purposes. Please
disclose the
         company's fiscal year-end in the notes to your financial statements in
your next
         amendment.

        You may contact Joanna Lam, Staff Accountant at 202-551-3476 or Craig
Arakawa,
Accounting Branch Chief, at 202-551-3650 if you have questions regarding
comments on the
financial statements and related matters. Please contact Irene
Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Tim Levenberg, Special Counsel, at 202-551-3707
with any other
questions.



FirstName LastNameMichael Silvestrini                          Sincerely,
Comapany NameEnergea Portfolio 1 LLC
                                                               Division of
Corporation Finance
June 15, 2020 Page 2                                           Office of Energy
& Transportation
FirstName LastName