SecProbe.io

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                                                   EDAC Technologies Corporation
                                                   1806 New Britain Ave.
                                                   Farmington, CT  06032
                                                   860-677-2603
                                                   Fax 860-674-2718

July 20, 2005

Mr. Joseph Foti
Senior Assistant Chief Accountant
Division of Corporate Finance
United States Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC  20549

Re:      Securities and Exchange Commission
         Letter dated June 24, 2005
         EDAC Technologies Corporation   File No. 0-14275
         Form 10-K for the year ended January 1, 2005
         Form 10-Q for the Quarterly Period Ended April 2, 2005

Dear Mr. Joseph Foti:

         The following are the responses of EDAC Technologies Corporation ("the
Company") to the comments in the Securities and Exchange Commission ("SEC")
Staff's comment letter dated June 24, 2005 (the "Comment Letter" relating to the
Company's Form 10-K for the year ended January 1, 2005 (the "Form 10-K") and the
Company's Form 10-Q for the quarter ended April 2, 2005 (the "Form 10-Q"). The
numbered responses below correspond to the numbered paragraphs in the Comment
Letter.

         Thank you for extending the due date of our response to July 20th in
the July 11th phone conversation between EDAC's Mr. Purple and Mr. Sears of your
office.

Selected Financial Information

1. Proposed additional disclosure to the Selected Financial Information:

         Net income (loss) amounts include the following items (amounts in
thousands): 2004, a tax benefit due to a reduction to the Company's income tax
valuation allowance in the amount of $1,432, an additional tax benefit due to
the determination of an income tax receivable in the amount of $331 and a gain
on debt forgiveness of $250; 2003, a gain on debt restructuring in the amount of
$7,253; 2002 a charge to income due to the cumulative effect of adoption of SFAS
No. 142 in the amount of $10,381 and a write-down for certain land, building and
equipment held for sale in the amount of $692; 2001,

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a gain on debt restructuring in the amount of $4,224; 2000, a charge to income
due to the cumulative effect of adoption of SAB 101 in the amount of $224.

         Revenues declined significantly from 2001 to 2002 due to a rapid
decline in the ground based turbine and commercial jet engine markets.

         Total assets declined significantly from 2001 to 2002 due to the charge
to income in the 1st quarter of 2002 of the cumulative effect of adoption of
SFAS No. 142 in the amount of $10,381.

Management Discussion and Analysis of Financial Condition and Results of
Operations

Results of Operations

2. Proposed additional disclosure to the Results of Operations section of the
Management Discussion and Analysis and Results of Operations:

Sales and sales increases for 2004 compared to 2003 by product line were as
follows (in thousands):

<Table>
<Caption>
    Product Line                           2004           2003          Change
---------------------                   ----------     ----------     ----------
<S>                                     <C>            <C>            <C>
Precision Aerospace                     $    9,070     $    7,644     $    1,426

Gros-Ite Spindles                            3,294          3,153            141

Apex Machine Tool Co.                       20,883         14,880          6,003
                                        ----------     ----------     ----------

Total                                   $   33,247     $   25,677     $    7,570
                                        ==========     ==========     ==========
</Table>

         Sales for the Precision Aerospace product line increased $1,426,000, or
18.7%, to $9,070,000 in 2004 compared to $7,644,000 in 2003. This increase is
due primarily to increased large commercial jet engine demand in 2004.
Conditions in the aerospace industry improved in 2004 resulting in increased
sales for the industry compared to 2003. Industry forecasts for the aerospace
industry for 2005 indicate continued improvement and increased sales for the
industry for 2005. The Company believes that the industry demand will continue
to increase for large commercial engines and has planned over $1 million in
capital expenditures for 2005 to increase its machining capacity for large
commercial jet engine parts.

         While the Precision Aerospace product line sales increased, sales of
non-jet engine parts to aerospace customers decreased in 2004 compared to 2003
resulting in the decrease of $565,000 in sales to aerospace customers. This
decrease was due to a reduction in demand on a tooling program from one of the
Company's aerospace customers. The Company believes, based on indications from
this customer, that tooling demand from this customer in 2005 will be consistent
with 2004.

         Sales for the Apex Machine Tool Co. product line increased $6,003,000,
or 40.3%, to $20,883,000 in 2004 compared to $14,880,000 in 2003. This increase
is due to

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increased demand on certain tooling programs from a customer in the consumer
products industry, offset by a decrease in demand for tooling from an aerospace
customer. Projections from the Company's consumer products customer and
aerospace customers indicate that both markets will have a steady level of
demand for 2005 compared to 2004.

         Sales for the Gros-Ite Spindle product line increased $141,000, or
4.5%, to $3,294,000 in 2004 compared to $3,153,000 in 2003. This product line
consists of both the sales of new spindles and the repair of all brands of
spindles. The increase in sales was due to increased demand for both new
spindles and the repair of spindles from customers in the automotive industry.
The Company believes that the demand will remain steady in 2005 based on
indications from its customers.

3. Proposed additional disclosure to the Results of Operations section of the
Management Discussion and Analysis and Results of Operations:

         In the 4th quarter 2004, the Company recorded sales of $596 for
delivery on an order for a large quantity of a certain military jet engine part,
and $564 for tooling delivered on a certain contract. Both contracts were with
the Company's largest aerospace customer. Production on both of these orders
commenced early in the third quarter of 2004 with delivery being made and the
sale recorded in the 4th quarter. Based on discussions held with the customer,
the Company anticipates orders in 2005 from the customer for the same jet engine
part, but not at the quantity ordered in 2004, due to the customer's
requirements.

Note G - Income Taxes, page 28

4. We confirm that we will expand our disclosures in the "Critical Accounting
Policies and Estimates" section to include information similar to that provided
in our response to your prior letter.

         Proposed additional disclosure to the "Critical Accounting Policies and
Estimates" section:

         In determining the portion of the deferred tax asset balance the
Company will "more likely than not realize", the Company considered the
following factors and assumptions:

         a)       The trend of earnings has been toward increased profitability
                  for the past two years. We assume that this trend will
                  continue.

         b)       The significant loss for 2002 was very unusual in that it
                  resulted from a 42% decrease in sales from 2001 due the rapid
                  decline of the ground-based turbine market and the commercial
                  jet engine market. We assume that this type of occurrence will
                  not repeat.

         c)       We assume projected operating profitability for 2005.

         d)       Debt in the amount of $750,000 will be forgiven on April 1,
                  2005, for which a $293,000 deferred tax asset has been
                  recorded.

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Note I - Segment Information, page 29

5. Proposed additional disclosure to Note I of the Notes to the Financial
Statements:

         Net sales for fiscal 2004, 2003 and 2002 by product line are as follows
(in thousands):

<Table>
<Caption>
                                           2004           2003           2002
                                        ----------     ----------     ----------
<S>                                     <C>            <C>            <C>
Net sales:

  Apex Machine Tool                         20,883         14,880         12,200
  Precision Aerospace                        9,070          7,644         10,830
  Gros-Ite Spindles                          3,294          3,153          2,820
                                        ----------     ----------     ----------

    Total                                   33,247         25,677         25,850
</Table>

Form 10-Q for the period April 2, 2005

6. We confirm that we will address your comments in our 10-Q filings where
applicable.

Condensed Consolidated Statements of Cash Flows

7. The refinancing of debt held with the our former primary lender with
financing from Banknorth N.A. was not included in the statement of cash flows as
it did not result in cash receipts or cash payments. We also did not include the
refinancing as supplemental information regarding non-cash financing activities
in accordance with paragraph 32 of SFAS No. 95, since the refinancing exchanged
debt for debt. Therefore we believe that a revision is not necessary.

Other

8. The proposed additional disclosures are included under each number above.

         The Company acknowledges the following with the Commission:

         o        the Company is responsible for the adequacy and accuracy of
                  the disclosure in the filings.

         o        staff comments or changes to disclosure in response to staff
                  comments in the filings reviewed by the staff do not foreclose
                  the Commission from taking any action with respect to the
                  filing; and

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         o        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.

                                           Sincerely,

                                           /s/Dominick A. Pagano
                                           Dominick A. Pagano
                                           President and Chief Executive Officer

cc: Mr. Glenn L. Purple
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