Exhibit 31


            CERTIFICATION OF BLAIR R. COUEY, CHIEF EXECUTIVE OFFICER
                 AND ACTING CHIEF FINANCIAL OFFICER, PURSUANT TO
            RULE 13a-14(a) UNDER THE SECURITIES EXCHANGE ACT OF 1934

I, Blair R. Couey, certify that:

1.       I have reviewed this annual report on Form 10-K of Evans Systems, Inc.;

2.       Based on my knowledge, this report does not contain any untrue
         statement of a material fact or omit to state a material fact necessary
         to make the statements made, in light of the circumstances under which
         such statements were made, not misleading with respect to the period
         covered by this report;

3.       Based on my knowledge, the financial statements, and other financial
         information included in this report, fairly present in all material
         respects the financial condition, results of operations and cash flows
         of the registrant as of, and for, the periods presented in this report;

4.       I am responsible for establishing and maintaining disclosure controls
         and procedures (as defined in Exchange Act Rules 13a-15(e) and
         15d-15(e)) and internal control over financial reporting (as defined in
         Exchange Act Rules 13a-15(f) and 15d-15(f)) for the registrant and
         have:

          a)   Designed such disclosure controls and procedures, or caused such
               disclosure controls and procedures to be designed under my
               supervision, to ensure that material information relating to the
               registrant, including its consolidated subsidiaries, is made
               known to me by others within those entities, particularly during
               the period in which this report is being prepared;
          b)   Designed such internal control over financial reporting, or
               caused such internal control over financial reporting to be
               designed under my supervision, to provide reasonable assurance
               regarding the reliability of financial reporting and the
               preparation of financial statements for external purposes in
               accordance with generally accepted accounting principles;
          c)   Evaluated the effectiveness of the registrant's disclosure
               controls and procedures and presented in this report my
               conclusions about the effectiveness of the disclosure controls
               and procedures, as of the end of the period covered by this
               report based on such evaluation; and
          d)   Disclosed in this report any change in the registrant's internal
               control over financial reporting that occurred during the
               registrant's most recent fiscal quarter (the registrant's fourth
               fiscal quarter in the case of an annual report) that has
               materially affected, or is reasonably likely to materially
               affect, the registrant's internal control over financial
               reporting; and

5.       I have disclosed, based on our most recent evaluation of internal
         control over financial reporting, to the registrant's auditors and the
         audit committee of the registrant's board of directors (or persons
         performing the equivalent functions):

          a)   All significant deficiencies and material weaknesses in the
               design or operation of internal control over financial reporting
               which are reasonably likely to adversely affect the registrant's
               ability to record, process, summarize and report financial
               information; and
          b)   Any fraud, whether or not material, that involves management or
               other employees who have a significant role in the registrant's
               internal control over financial reporting.

Date: January 13, 2005

By: /s/ Blair R. Couey
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Blair R. Couey
President, Chief Executive Officer
and Acting Chief Financial Officer