SecProbe.io

March 11, 2014
Via E-mail
Mr. Stephen M . Kadenacy
Chief Financial Officer
AECOM Technology Corporation
555 South Flower Street, Suite 3700
Los Angeles , CA 90071

Re: AECOM Technology Corporation
 Form 10 -K for Fiscal Year Ended September 30 , 2013
Filed November 1 3, 2013
Form 10 -Q for Fiscal Quarter Ended December 31, 2013
Filed February 5, 2014
File No. 0-52423

Dear Mr. Kadenacy :

We have reviewed your filing s and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within ten business days by providing the requested
information or by ad vising us when you will provide the requested response.   If you do not
believe our comments apply to your facts and circumstances, please tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10 -K for Fiscal Year Ended September 30 , 2013

General

1. You told us in your letter to us dated April 15, 2011 that your subsidiaries worked on
various projects in Sudan and Syria, and that you expected to engage in future pr ojects in
Sudan and to complete your existing projects in Syria.   Also, we note from your website
that you continue to be involved in projects in Sudan.   As you know, Sudan and Syria are
designated as state sponsors of terrorism by the State Department and  are subject to U.S.
economic sanctions and export controls.   Your Form 10 -K does not include disclosure
regarding any contacts with Sudan or Syria.   Please provide us with information
regarding your contacts with Sudan and Syria since the referenced lette r.  Your response
should describe any goods, technology, services, or support you have provided into
Sudan and Syria, directly or indirectly, and any agreements, arrangements, or other
contacts you have had with the governments of Sudan and Syria or entiti es they control.

Mr. Stephen M. Kadenacy
AECOM Technology Corporation
March 11, 2014
Page 2

 2. Please discuss the materiality of your contacts with Sudan and Syria described in
response to the foregoing comment, and whether they constitute a material investment
risk for your security holders.   You should address materiality in quant itative terms,
including the approximate dollar amounts of any revenues, assets, and liabilities
associated with Sudan and Syria for the last three fiscal years and the subsequent interim
period.   Also, address materiality in terms of qualitative factors t hat a reasonable investor
would deem important in making an investment decision, including the potential impact
of corporate activities upon a company’s reputation and share value.   As you know,
various state and municipal governments, universities, and ot her investors have proposed
or adopted divestment or similar initiatives regarding investment in companies that do
business with U.S. -designated state sponsors of terrorism.   Your materiality analysis
should address the potential impact of the investor sen timent evidenced by such actions
directed toward companies that have operations associated with Sudan and Syria.

Risk Factors, page 13

Our failure to meet contractual schedule or performance requirements…, page 17

3. Regarding your revenue agreements perta ining to events of defaults and remedies, in
future filings please disclose in the risk factor whether losses related to such defaults and
remedies, including liquidated damages clauses, have materially impacted your operating
results in any of the periods  presented.  Absent such disclosure, it is unclear how
investors can fully assess the likelihood of the risk factor having a material impact.  If
material, such losses should be quantified in the filing and your revenue recognition
policy disclosures shoul d be expanded to specifically state how these loss contingencies
impact your revenue recognition policies.   Please provide us with an example of your
intended future disclosure.

Form 10 -Q for Fiscal Quarter Ended December 31, 2013

Note 6 – Joint Ventures and Variable Interest Entities, page 8

4. Per our comment letter dated March 22, 2013, for your unconsolidated joint ventures in
future filings please include (a) gross profit, (b) net income and (c) net income
attributable to AECOM required by Article 1 -02(bb)(1)(ii) of Regulation S -X.

5. In connection with recording the $37.4 million gain upon change in control of your
unconsolidated joint ventu re, please provide us (1) the original joint venture operating
agreement, (2) the modified joint venture agreement, and (3) your analysis and
identification of the specific terms in the agreements that substantiate non -consolidation
under the original agre ement and consolidation under the modified agreement.  Please
reference the authoritative accounting guidance which supports your accounting.

Mr. Stephen M. Kadenacy
AECOM Technology Corporation
March 11, 2014
Page 3

 Also, please quantify for us the dollar amounts of sales, operating income, and total
assets of any joint venture s that were either newly consolidated or newly deconsolidated
during fiscal years 2013 and 2014 to date.

Note 16 – Commitments and Contingencies, page 18

AECOM Australia , page 18

6. Please supplementally justify your statement on page 31 that “none of the investigations,
claims and lawsuits in which we are involved is expected to have a material adverse
effect  [emphasis added] on our consolidated financial position, results of operations, cash
flows or our ability to conduct business.”  Also, should this be  deemed a material legal
proceeding, disclose the factual basis alleged to underlie the proceeding and the relief
sought required by Item 103 of Regulation S -K and Section 501.13 of the Financial
Reporting Codification Policies in Legal Proceedings and in this note to the financial
statements.

7. Further, please tell us supplementally  whether a probable loss has been accrued, and if so,
the dollar amount; if a loss has not been recorded, please tell us  why.  If there is at least a
reasonable possibility you may have incurred a loss exceeding the amount already
accrued (if any), please  revise future filings to  either disclose an estimate of the
additional loss or range of loss (or, if true, state that the estimate is immaterial in lieu of
providing quantified amounts), or state that such an estimate ca nnot be made.  Refer to
ASC 450 -20-50.  Please provide us with any proposed revisions to future disclosure.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exch ange Act rules 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 responding to our comments, please  provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 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.

Mr. Stephen M. Kadenacy
AECOM Technology Corporation
March 11, 2014
Page 4

You may contact Th omas D’Orazio at (202) 551 -3825 , Al Pavot  at (202) 551 -3738 or the
undersigned Accounting Branch Chief at  (202) 551 -3355  if you have questions regarding
comments on the financial statements and related matters.  For other comments, please contact
Sherry Haywood at (202) 551 -3345 or Craig Slivka, Special Counsel, at (202) 551 -3729.

Sincerely,

 /s/ Terence O ’Brien

Terence O’Brien
Accounting Branch Chief