SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-4631

       DIVISION OF
CORPORATION FINANCE

Mail Stop 4631
October 28, 2009

via U.S. mail and facsimile

John M. Dionis, Chief Executive Officer  AECOM Technology Corp  555 South Flower Street, Suite 3700 Los Angeles, California 90071    RE: AECOM Technology Corp
  Form 10-K/A for the Fiscal  Year Ended September 30, 2008
  Filed January 23, 2009   Proxy Statement    Filed January 23, 2008   File No. 000-52423

Dear Mr. Dionis:

We have reviewed your response letter  dated October 9, 2009 and have the
following additional comments. If you disagree , we will consider your explanation as to
why our comment is inapplicable.

 Form 10-K for the Fiscal Year Ended September 30, 2008

 21.  Reportable Segments and Geographic Information, page 89

1. We have read your response to comment 1 from our letter dated September 16,
2009.  We appreciate the additional inform ation you have provided to help us
understand how your assessment that the seven operating segments comprising
the PTS segment can be aggregated into one reportable segment in accordance with paragraph 17 of SFAS 131.   In an effort to better understand the dynamics
of your operating segments, please  provide  us with a matrix that demonstrates
how your seven operating segments within the PTS segment correlate to the key
end markets discussed on pages 3-5 of  your fiscal year 2008 Form 10-K.
Specifically, please tell us the amount of total revenue recognized by each of the
operating segments for each of the key end markets discussed for fiscal years 2008 and 2007 and the quarters ended December 31, 2008, March 31, 2009 and June 30, 2009 in a table format.

Mr. Dionis
AECOM Technology Corp October 28, 2009 Page 2
2. We note your description of the seven operating segments within the PTS
segment in comment 2 from our letter dated September 16, 2009.  Please provide
us with a better understandi ng of the differences betw een each of these operating
segments.  In this regard, it appears fr om your descriptions that your operating
segments may be based on geograp hic locations.  Please advise.

*    *    *    *

As appropriate, please respond to these co mments within 10 business days or tell
us when you will provide us with a response.  Please furnish a letter that keys your
responses to our comments and provides any requested supplemental information.
Detailed response letters  greatly facilitate our  review.  Please file your response letter on
EDGAR.  Please understand that we may ha ve additional comments after reviewing
responses to our comments.   You may contact Tracey McKoy, Staff A ccountant, at (202) 551-3772 or, in her
absence Tracey Houser at (202) 551-3736 or the undersigned Accounting Branch Chief at
(202) 551-3355 if you have questions regard ing comments on the financial statements
and related matters. Please contact Dorine Mi ller at (202) 551-3711 wi th any legal related
questions.

Sincerely,
           T e r e n c e  O ’ B r i e n          A c c o u n t i n g  B r a n c h  C h i e f