Mail Stop 4561
November 22, 2005

Mr. Michael Schumacher
President
Birch Branch, Inc.
2525 Fifteenth Street, Suite 3H
Denver, CO 80211

Re:	Birch Branch, Inc.
      Amendment No. 2 to Form SB-2
      Filed November 8, 2005
      File No. 333-126654


Dear Mr. Schumacher:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

General
1. Please update your financial statements pursuant to Item 310(g)
of
Regulation S-B.

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please understand
that we may have additional comments after reviewing your
amendment
and responses to our comments.


      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Matthew Maulbeck, Accountant, at (202) 551-
3466
or Steven Jacobs, Accounting Branch Chief, at (202) 551-3403 if
you
have questions regarding comments on the financial statements and
related matters.  Please contact David Roberts, Staff Attorney, at
(202) 551-3856 or the undersigned at (202) 551-3780 with any other
questions.



      Sincerely,



      Karen J. Garnett
      Assistant Director



cc:	Clifford L. Neuman (via facsimile)

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Michael Schumacher
Birch Branch, Inc.
November 22, 2005
Page 1