[ALTERNATIVE TECHNOLOGY RESOURCES, INC. LETTERHEAD]

                                 January 8, 2004

VIA EDGAR

Division of Corporate Finance
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

         Re:      Application for Withdrawal of Registration Statement on
                  Form S-1 (No. 333-53820)

Dear Sir/Madam:

     Pursuant  to Rule 477 under the  Securities  Act of 1933,  as amended  (the
"1933 Act"), the Company hereby respectfully  requests that the above referenced
Registration Statement be withdrawn and that an order of the Commission granting
such withdrawal be granted.

     The  withdrawal of the  Registration  Statement is requested on the grounds
that the offer  and sale of the up to  20,604,773  shares  of  common  stock the
selling  stockholders  named therein including  1,237,138 shares of common stock
that may be resold by selling  stockholders  upon the  exercise  of  outstanding
warrants  and upon the  conversion  of  convertible  notes  could no  longer  be
effected  pursuant  to the  Registration  Statement  due to the  fact  that  the
Registration  Statement has not been amended to update the information  included
therein since the  Registration  Statement  was declared  effective on April 13,
2001. As a result,  all of the selling  shareholders have been advised that they
can no  longer  sell  their  shares  of  common  stock  under  the  Registration
Statement.  Accordingly, the Company respectfully submits that the withdrawal of
the outdated  Registration  Statement is consistent with the public interest and
the protection of investors.

     Should  you have any  questions  or  comments,  please do not  hesitate  to
contact Daniel B. Eng, Esq. of Bartel Eng & Schroder, a Law Corporation, counsel
to the Company, at (916) 442-0400.

                                          Very truly yours,

                                          Alternative Technology Resources, Inc.


                                          By:  /s/ Mark W. Rieger
                                              ----------------------------------
                                                Mark W. Rieger
                                                Chief Executive Officer