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March 17, 2023
Michael W. Metcalf
Chief Financial Officer
Powell Industries, Inc.
8550 Mosley Road
Houston, TX 77075-1180
Re:Powell Industries, Inc.
Form 10-K for the Fiscal Year Ended September 30, 2022
Filed December 6, 2022
Form 8-K, Filed January 31, 2023
File No. 001-12488
Dear Michael W. Metcalf:
            We have limited our review of your filing to the financial statements and related
disclosures 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 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.
Form 10-K for the Fiscal Year Ended September 30, 2022
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 20
1.We note from your disclosure in Note E that a significant amount of your revenue is
generated from long-term fixed price contracts that is generally recognized over time
utilizing the cost-to-cost method. Under the cost-to-cost method, the extent of progress
towards completion is measured based on the ratio of costs incurred to date to the total
estimated costs at completion of the performance obligation.  We also note your
disclosure that for the years ended September 30, 2022 and 2021, your operating results
were positively impacted by $ 11.3 million and $ 12.5 million, respectively, as a result of
changes in contract estimates related to projects in progress at the beginning of the
respective period.  Please revise your results of operations disclosure in MD&A to
separately quantify gross favorable and gross unfavorable changes in estimates material to

 FirstName LastNameMichael W.  Metcalf
 Comapany NamePowell Industries, Inc.
 March 17, 2023 Page 2
 FirstName LastNameMichael W.  Metcalf
Powell Industries, Inc.
March 17, 2023
Page 2
your results, accompanied by an appropriate level of analysis.
2.We note your disclosure that gross profit increased by 13%, or $10.0 million, to $85.0
million in fiscal 2022, but despite the increase in revenues, gross profit as a percentage of
revenues remained flat to the prior fiscal year at 16% in fiscal 2022 due to increased costs
impacting older projects in your backlog that were subject to inflationary pressures on raw
materials and components, with little or no recourse from the customer to reprice the
project.  We also note that favorable project execution, volume leverage and product mix,
including fast track service and replacement projects across your service division, all
helped to offset the negative inflationary pressure carried by the older projects in the
backlog.  In future filings where you describe two or more factors that contributed to a
material change in a financial statement line item between periods, especially when there
are offsetting amounts, please quantify each material factor that contributed to the overall
change in that line item. Refer to Item 303 of Regulation S-K and Section III.D of SEC
Release No. 33-6835.
Consolidated Statements of Operations, page 33
3.We note from your disclosure in Note E on page 43 that in addition to manufacturing
custom-engineered products and systems, you recognize revenue from contracts  to
provide field service inspection, installation, commissioning, modification, and repair
services, as well as retrofit and retrofill components for existing systems.  We also note
from some of the discussion during the year end 2022 earnings call, that this service
revenue was a significant contributor to your business during 2022.  Please tell us the
amount of revenue related to services as compared to products for the year ended
September 30, 2022.  If the amount is greater than 10% of the consolidated revenue
amount, please revise future filings to separately present revenue and cost of goods sold
for products and services.  See requirement in Rule 5-03(b)(1) and (b)(2) of Regulation S-
X.
Form 8-K Furnished January 31, 2023
Exhibit 99.1 Earnings Release, page 1
4.We note that your Key Highlights section at the top of your earnings release includes the
disclosure of your book-to-bill ratio.   Please disclose how you compute the book-to-
bill ratio and explain the significance of this ratio in understanding your business.  As part
of your disclosure, please define "new orders" and disclose any limitations on the new
orders amounts, such as any pertinent termination clauses or contingencies, that may
ultimately impact the realizations of such amounts as revenues.  Refer to the metrics
guidance set forth in SEC Release No. 33-10751.
            In closing, 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.

 FirstName LastNameMichael W.  Metcalf
 Comapany NamePowell Industries, Inc.
 March 17, 2023 Page 3
 FirstName LastName
Michael W.  Metcalf
Powell Industries, Inc.
March 17, 2023
Page 3
            You may contact Beverly Singleton at (202) 551-3328 or Claire Erlanger at (202) 551-
3301 with any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing