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Tech/Ops Sevcon, Inc.
155 Northboro Road
Soutborough
MA 01772

Tel  (508) 281 5510
Fax (508) 281 5520

www.techopssevcon.com

Mr. M. James
Senior Assistant Chief Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
U.S.A.

February 14, 2005

Dear Mr. James,

On behalf of Tech/Ops Sevcon, Inc. (the "Company"), we are transmitting
herewith for filing under the Securities Exchange Act of 1934 a Form 10-K/A
with respect to the fiscal year ended September 30, 2004.

The following responds to, and provides supplemental information required by,
your letter to me of January 31, 2005, regarding the Form 10-K for the year
ended September 30, 2004 that the Company filed with the Commission on
December 27, 2004. We are sending courtesy copies of this letter and the
Form 10-K/A, marked to indicate the change made to the Form 10-K as
requested, by fax to you and to Ms. Julie Sherman.

Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations

Critical Accounting Estimates

1.   In future filings please revise the discussion of the bad debts and
     inventories discussions, to identify the estimates used and to describe
     the methodology used to determine the bad debt and inventory
     obsolescence reserves. Explain how changes in these estimates could
     impact the provisions recorded in each period.

     Response

     We will revise the bad debts and inventories discussions in future
     filings, to identify the estimates used and to describe the methodology
     used to determine the bad debt and inventory obsolescence reserves. We
     will explain how changes in these estimates could impact the provisions
     recorded in each period. In future filing we will provide disclosure in
     substantially the following form.  The changed wording has been
     underlined.

     Bad Debts

     The Company estimates an allowance for doubtful accounts based on known
     factors related to the credit risk of each customer and management's
     judgment about the customer's business. Ten customers account for
     approximately 56% of the Company's sales. At September 30, 2004 the
     allowance for bad debts amounted to $192,000, which represented 3% of
     receivables.

     Because of the Company's long term relationships with the majority of
     its customers, in most cases, the principal bad debt risk to the Company
     arises from the insolvency of a customer rather than its unwillingness
     to pay. In addition, in certain cases the Company maintains credit
     insurance covering up to 90% of the amount outstanding from specific
     customers. The Company also carries out some of its foreign trade,
     particularly in the Far East, using letters of credit.

     The Company reviews all accounts receivable balances on a regular basis,
     concentrating on any balances that are more than 30 days overdue, or
     where there is an identified credit risk with a specific customer. A
     decision is taken on a customer-by-customer basis as to whether a bad
     debt reserve is considered necessary based on the specific facts and
     circumstances of each account. In general, the Company would reserve
     100% of the receivable, net of any recoverable value added taxes or
     insurance coverages, for a customer that becomes insolvent or files for
     bankruptcy, and lesser amounts for less imminent defaults. To a lesser
     degree, the Company  maintains a small bad debt reserve to cover the
     remaining balances based on historical default percentages.

     If the financial condition of any of the Company's customers is worse
     than estimated or were to deteriorate, resulting in an impairment of its
     ability to make payments, the Company's results may be adversely
     affected and additional allowances may be required. With the exception
     of a significant loss of $562,000 in fiscal 2001 relating to one US
     customer, credit losses have not been significant in the past ten years.

     Inventories

     Inventories are valued at the lower of cost or market. Inventory costs
     include materials, direct labor and manufacturing overhead, and are
     relieved from inventory on a first-in, first-out basis. The Company
     carries out a significant amount of customization of standard products
     and also designs and manufactures special products to meet the unique
     requirements of its customers. This results in a significant proportion
     of the Company's inventory being customer specific. The Company's
     reported financial condition includes a provision for estimated slow-
     moving and obsolete inventory that is based on a comparison of inventory
     levels with forecast future demand. Such demand is estimated based on
     many factors, including management judgments, relating to each
     customer's business and to economic conditions. The Company reviews in
     detail all significant inventory items with holdings in excess of
     estimated normal requirements. It also considers the likely impact of
     changing technology. It makes an estimate of the provision for slow
     moving and obsolete stock on an item-by-item basis based on a
     combination of likely usage based on forecast customer demand, potential
     sale or scrap value and possible alternative use. This provision
     represents the difference between original cost and market value at the
     end of the financial period. In cases where there is no estimated future
     use for the inventory item and there is no estimated scrap or resale
     value, a 100% provision is recorded. Where the Company estimates that
     only part of the total holding of an inventory item will not be used, or
     there is an estimated scrap, resale or alternate use value, then a
     proportionate provision is recorded. Once an item has been written down,
     it is not subsequently revalued upwards. The provision for slow moving
     and obsolete inventories at September 30, 2004 was $879,000, or 18% of
     the original cost of gross inventory. At September 30, 2003 the
     provision was $737,000, or 15% of gross inventory. If actual future
     demand or market conditions are less favorable than those projected by
     management, or if product designs change more quickly than forecast,
     additional inventory write-downs may be required, which may have a
     material adverse impact on reported results.

Results of Operations

2.   In future filings, consider presenting a tabular comparison of your
     results in different periods by operating segment, with percentage
     changes, followed by your narrative discussion and analysis of the
     reasons for material changes and their implications. Refer to SEC
     Release No. 34-48960.

     Response

     In future filings we will provide a table in the MD&A in substantially
     the following form:

                                                     % change due to:
                                                                  Volume/
                                 2004      2003   Total  Currency  other
Sales
  Controls - to external
    customers                  27,101    20,730     31%        9%    22%
  Capacitors- to external
    customers                   2,049     2,383    -14%       10%   -24%
  Capacitors - inter-segment      218       326    -33%        7%   -40%
-------------------------------------------------------------------------
  Capacitors - total            2,267     2,709    -16%       10%   -26%
-------------------------------------------------------------------------
  Total sales to external
    customers                  29,150    23,113     26%        9%    17%
-------------------------------------------------------------------------

Gross Profit
  Controls                     10,546     7,510     40%        3%    38%
  Capacitors                      999     1,295    -23%        8%   -31%
-------------------------------------------------------------------------
  Total                        11,545     8,805     31%        4%    27%
-------------------------------------------------------------------------

Selling general and
  administrative expenses
    Controls                    9,572     7,563     27%        9%    18%
    Capacitors                    704       819    -14%        8%   -22%
    Unallocated corporate
      expense                    (297)     (272)     9%        0%     9%
-------------------------------------------------------------------------
  Total                        10,573     8,654     22%        8%    14%
-------------------------------------------------------------------------

Operating income
  Controls                        974       (53) -1938%      830% -2768%
  Capacitors                      295       476    -38%        8%   -46%
  Unallocated corporate expense  (297)     (272)     9%        0%     9%
-------------------------------------------------------------------------
  Total                           972       151    544%     -265%   809%
-------------------------------------------------------------------------

Other income and expense          (54)      (23)   135%      248%  -113%
-------------------------------------------------------------------------
Income before income taxes        918       128    617%     -357%   974%
Income taxes                     (307)      (45)   582%     -337%   919%
-------------------------------------------------------------------------
Net Income                        611        83    636%     -368%  1004%
-------------------------------------------------------------------------

Item 7A. Quantitative and Qualitative Disclosures about Market Risk

3.   In future filings please expand your discussion of foreign currency
     exchange rate market risk to include quantitative information in
     accordance with one of the three disclosure alternatives outlined in
     Item 305 of Regulation S-K.

     Response

     In future filings we will include such information in accordance with
     one of the three disclosure alternatives outlined in Item 305 of
     Regulation S-K.

4.   In addition, we note your reference to Note (1) J., and refer you to
     General Instruction No. 6 to paragraph 305(a) and 305(b) of Regulation
     S-K which clearly states that you should present all the information
     called for by the item outside of the financial statements. Please
     confirm that you will comply with that guidance in all future filings.

     Response

     We agree. In future filings we will incorporate the necessary
     information in management's discussion and analysis rather than cross
     refer to the financial statement footnotes.

Consolidated Balance Sheet

5.   We noted that other accrued expenses represent approximately 26% of
     total current liabilities. Supplementally, and in future filings, please
     state separately, in the balance sheet or in a note, any item included
     in accrued liabilities which is in excess of 5 percent of total current
     liabilities in accordance with Regulation S-X Article 5-02(20).

     Response

     We agree. Set out below is an analysis of accrued expenses, including
     accrued compensation and related costs, at September 30, 2004 and 2003,
     which shows separately any items in excess of 5% of total current
     liabilities. In future filings we will combine accrued compensation and
     related costs with other accrued expenses on a singe line in the balance
     sheet labeled "Accrued expenses" and we will include a footnote which
     provides an analysis of Accrued expenses substantially in the following
     form:

X.  Accrued expenses

     Set out below is an analysis of other accrued expenses at September 30,
     2004 and 2003 which shows separately any items in excess of 5% of total
     current liabilities.

                                                   (In thousands of dollars)
     -----------------------------------------------------------------------
                                                          2004         2003
     -----------------------------------------------------------------------
     Accrued compensation and related costs            $   979      $   792
     Warranty reserves                                     386          404
     Accrued director's pension                            201          205
     Other accrued expenses                                975          922
     -----------------------------------------------------------------------
     Total                                             $ 2,541      $ 2,323
     -----------------------------------------------------------------------

Note 1. Summary of Significant Accounting Policies

B.   Revenue Recognition

6.   We noted that the company provides warranties for customers. Please
     revise future filings to provide the disclosures required by paragraph
     14 of FIN 45.

     Response

     We agree. In future filings we will include a footnote which provides an
     analysis of product warranties, as required by paragraph 14 of FIN 45,
     substantially in the following form:

X.   Warranty Reserves

                                                   (In thousands of dollars)
     -----------------------------------------------------------------------
                                                          2004         2003
     -----------------------------------------------------------------------
     Balance at beginning of year                      $   404      $   296
     Decrease in opening balance for warranty
       obligations settled during the year                (331)        (xxx)
     Other changes to pre-existing warranties                6           xx
     Net increase in warranty reserves for
       products sold during the year                       307          xxx
     -----------------------------------------------------------------------
     Balance at end of year                            $   386      $   404
     -----------------------------------------------------------------------

E.   Stock-Based Compensation Plans

7.   In future filings please ensure your pro forma table is presented in
     accordance with paragraph 2(e)(c) of SFAS 148. Your current presentation
     does not show the stock based employee compensation cost included in the
     determination of net income as reported or the stock based employee
     compensation cost that would have been included in the determination of
     net income if the fair value based method had been applied to all
     awards.

     Response

     We agree. In future 10-K filings we will amend the table in footnote E
     ("Stock based compensation plans") substantially in the following form:

                                                   (In thousands of dollars)
     -----------------------------------------------------------------------
                                                     2004     2003     2002
     -----------------------------------------------------------------------
     Net income - As reported                      $  611   $   83   $   57
     Pro forma effect of expensing stock
       options (net of income tax)                    (66)     (66)     (53)
     -----------------------------------------------------------------------
     Net income - Pro forma                        $  545   $   17   $    4
     -----------------------------------------------------------------------
     Basic net income per share -  As reported     $  .20   $  .03   $  .02
     Basic net income per share - Pro forma        $  .17   $  .01   $  .00

     Diluted net income per share - As reported    $  .19   $  .03   $  .02
     Diluted net income per share - Pro forma      $  .17   $  .01   $  .00
     ---------------