SecProbe.io

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Mail Stop 0306

May 24, 2005

By U.S. Mail and facsimile to (423)899-4456

F. Mckamy Hall
Vice President, Chief Financial Officer and Treasurer
Astec Industries, Inc.
1725 Shepherd Road
Chattanooga, TN 37421

	RE:	Astec Industries, Inc.
		Form 10-K for the year ended December 31, 2004
		Form 10-Q for the quarter ended March 31, 2005
      File No. 000079987

Dear Mr. Hall:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and will make no further review of your
documents.  Where indicated, we think you should revise your
document
in future filings 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 year ended December 31, 2004

Financial Statements

Consolidated Balance Sheets
1. Show us that the item "other accrued liabilities" should not be
further disaggregated pursuant to Rule 5-02.20 to Regulation S-X.
2. The footnotes to future filings should present a clear
description
of the components of the item "accrued loss reserves."  The
footnote
disclosure about this item should also consider the requirements
of
SFAS 5, SOP 94-6 and SAB Topic 5-Y.  Show us how you plan to
implement this comment.

Consolidated Statements of Operations
3. When significant, MD&A or the notes to financial statements
should
present disclosure about the components of "other income (expense)
-
net."   We see, for instance, the significance of the "net"
amounts
for 2003 and 2002 and the significant variance between those
years.

Consolidated Statements of Cash Flows
4. We see investing cash flows from finance receivables and notes
receivable.  In a supplemental response, describe the transaction
cycles responsible for these cash flows.  If these cash flows were
derived from the sales of goods and services, explain why those
cash
flows should not be classified as operating activities.  Under
SFAS
95, operating cash flows include cash receipts from sales of goods
or
services, including receipts from collection or sale of accounts
and
both short- and long-term notes receivable (and leases) from
customers arising from those sales.  Show us that these cash flows
were not derived from sales of goods and services and show us that
they have been appropriately classified for cash flow statement
purposes.  Also respond with respect to the proceeds from and
expenditures for equipment on operating leases.  Show us that
those
cash flows are not operating activities as defined in SFAS 95.
5. We see a cash outflow totaling $1.8 million identified as "cash
paid for retirement of stock."  However, we do not see this item
on
the statement of shareholders` equity.  Tell us how the
disbursement
was accounted for, including where it is presented on the
statement
of shareholders` equity.

Note 1 - Summary of Significant Accounting Policies

Revenue Recognition
6. We note the general criteria you apply for product revenue
recognition purposes. We also see that you sell products through
dealers, independent representatives and distributors. Tell us
more
about the terms of sales through these channels. Do you recognize
revenue when you ship product to dealers, independent
representatives
and distributors or when these parties resell products to their
customers? Show us how you apply the disclosed criteria for
transactions with these parties and demonstrate to us that your
revenue practices are appropriate for transactions with these
parties. Be sure to address the considerations that drive the
timing
of revenue. Refer to SAB 104.
7. You disclose that you "generally" obtain purchase
authorizations
from customers specifying terms for product, price and delivery.
Tell us about the extent of exceptions to this policy, including
whether there is any impact on the underlying accounting. That is,
what happens when you do not have a written purchase
authorization?
8. Supplementally describe the nature, terms and extent of post
shipment obligations and customer acceptance protocols.  Tell us
how
these matters are considered in your revenue practices and show us
that your application is appropriate under SAB 104. To the extent
these considerations vary based on product, market or other
factor,
please be specific.
9. Supplementally quantify bill and hold sales for the periods
presented in the financial statements.  With respect to those
transactions, show us that you appropriately applied the criteria
from SAB 104 in accounting for the related revenue.  Specifically
identify the substantive business purpose for each significant
transaction.
10. In future filings, more specifically identify the
circumstances
when you apply multiple element accounting. Clarify the nature of
the
vendor specific objective evidence of fair value you consider in
applying that accounting.  Also, clarify the factors you evaluate
in
determining that the functionality of delivered elements is not
dependent on undelivered elements and clarify the factors you
consider in assessing whether delivery of the delivered element is
the culmination of the earnings process.  Respond supplementally,
as
well.

Note 13 - Contingencies
11. Please expand future filings to make more specific disclosure
about lawsuits and claims, including specific disclosure about
potentially significant individual matters. Refer to SFAS 5, SOP
94-6
and SAB Topic 5-Y.  Show us how you plan to implement this
comment.
If you believe your existing disclosure is compliant, support that
conclusion supplementally and in detail.

Note 16 - Operation by Industry Segment and Geographic Area
12. We see that the segment loss for "all others" significantly
increased in 2004. In future filings, the segment discussion in
MD&A
should also address this segment, including reasons for
significant
changes in corporate or other expenses included therein. Also
describe supplementally the factors leading the loss from this
segment to more than double in 2004.
13. Please expand future filings to also present long-lived assets
by
geographic area as required by paragraph 38(b) of SFAS 131.

*    *    *    *

      As appropriate, please respond to these comments within 10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
responses to our comments and provides any requested supplemental
information.  Detailed cover letters greatly facilitate our
review.
Please file your cover letter on EDGAR.  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 the filings;
* 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
* 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.

      You may contact Patrick Enunwaonye, Staff Accountant, at
(202)
551-3645 or me, at (202) 551-3605 if you have questions regarding
comments on the financial statements and related matters. In this
regard, do not hesitate to contact Brian Cascio,  Accounting
Branch
Chief , at (202) 551-3676 with any other concerns.

							Sincerely,

							Gary Todd
							Review Accountant
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Mr. Hall
Astec Industries, Inc.
May 24, 2005
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