SecProbe.io

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      Mail Stop 0510

      March 29, 2005

By U.S. Mail and facsimile to (203)849-7830

Mr. Leicle E. Chesser
Executive Vice President and Chief Financial Officer
Emcor Group, Inc.
301 Merritt Seven Corporate Park
Norwalk, CT 06851-1060

Re:	Emcor Group, Inc.
	Form 10-K for the year ended December 31, 2004
      File No. 1-8267

Dear Mr. Chesser:

      We have reviewed your filings 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 on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

FORM 10-K FOR THE PERIOD ENDED DECEMBER 31, 2004

Commission File Number

1. Please note that the registrant current Commission file number
is
1-8267.  Please use the correct file number on the cover page of
future reports.  Refer to your Form 8-A12 B filed on October 30,
2000.

Note B.  Summary of Significant Accounting Policies, page 30

Property, Plant and Equipment, page 32

2. In future filings, revise to disclose the useful lives for each
major class of depreciable assets.  The range you indicate of 2 to
40
years is too broad to be useful.

Goodwill and Identifiable Intangible Assets, page 32

3. In future filings, please disclose the date of your annual
assessment of goodwill for impairment.  Reference paragraph 26 of
SFAS 142 and APB Opinion 22.

Note G. Income Taxes, page 38

4. We note that you have a $22.1 reversal of previous tax reserves
in
fiscal 2004 since you believe that the tax reserve is no longer
required based upon current analysis of probable exposure.  Please
tell us supplementally the facts and circumstances surrounding
these
reserves and how you determined that such reserves were no longer
necessary.  We note that the reserves were reversed over several
quarters.  Therefore, in your response, please include a
discussion
of the facts and circumstances that led to each individual
reversal.

	Please respond to these comments within 10 business days, or
tell us when you will provide us with a response.  Please provide
us
with a supplemental response letter that keys your responses to
our
comments and provides any requested supplemental information.
Detailed letters greatly facilitate our review.  Please file your
supplemental response on EDGAR as a correspondence file.  Please
understand that we may have additional comments after reviewing
your
responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in their filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

     In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

     If you have any questions regarding these comments, please
direct them to Patricia Armelin, Staff Accountant, at (202) 824-
5563,
Nathan Cheney at (202) 942-1804 or, in their absence, to the
undersigned at (202) 824-5373.

      Sincerely,

      John Cash
      Accounting Branch Chief

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Mr. Leicle E. Chesser
March 29, 2005
Page 1 of 3

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-0510

         DIVISION OF
CORPORATION FINANCE

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