SecProbe.io

January 22 , 2015

Via E -mail
Mr. Stephen M. Kadenacy
Chief Financial Officer
AECOM
1999 Avenue of the Stars, Suite 2600
Los Angeles, California 90067

Re: AECOM Technology Corporation
 Form 10 -K for Fiscal Year Ended September 30, 2014
Filed November 17 , 2014
File No. 0-52423

Dear Mr. Kadenacy :

We have reviewed your filing an d have the following comments .  We have limited our
review to only your financial statements and related disclosures and do not intend to expand our
review to other portions of your documents .  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 b usiness days by providing the requested
information, or by advising us when you will p rovide 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 info rmation you provide in response to these comments, we may
have additional comments.

Form 10 -K for the period ended September 30, 2014

Item 7. Management’s Discussion and Analysis of Financial Condition –Results of Operations,
page 48

1. In fut ure filings please ensure that your discussion and analysis of segment results
provides investors with an understanding of all material factors contributing to the
changes and quantify those changes when providing your analysis. For example, your
discussio n and analysis of the Professional Technical Services segment’s gross profit
states that it decreased as a result of a decline in “revenue in engineering and program
management services in the Americas partially offset by the collection of a previously
reserved receivable .” If that variance materially impacted the Professional Technical
Services segment gross profit, then a thorough explanation of the material factors
contributing to the decline in the segment gross profit should be provided in order for
investors to fully understand the segment’s operating results. Additionally, please
quantify the amount of the previously collected receivable. It appears that amount may be

Mr. Kadenacy
AECOM
January 2 2, 2015
Page 2

 up to $6.8 million based on your Schedule II: Valuation and Qualifying Accounts
disclosure on page 118. Therefore, absent its collection it appears that the decrease in the
Professional Technical Services segment gross profit would have been greater than the
$51.7 million. If the entire remaining change is then attributed to the decline i n revenue
from the engineering and program management services in the Americas, then it would
appear that the gross profit on that piece would have contributed significantly more to the
gross profit line ($51.7 million plus the amount of the previously res erved receivable
divided by $120 million disclosed on page 49). As such, there appears to be a
disproportionate difference when compared to the disclosed gross profit percentage of
8.2% for that segment that should be fully explained. Please provide us wit h a revised
draft of the disclosure that you intend to include in your next Form 10 -K. Please refer to
Item 303(a)(3) of Regulation S -K and Section 501.12.b. of the Financial Reporting
Codification for guidance.

2. Similar to our comment 1 above , there appe ars to be a lack of discussion of your MSS
segment’s gross profit change  for the year . Specifically you state that MSS segment’s
gross profit increased primarily as a result of “a previously reserved Libya – related
project receivable offset by decreased s ervices provided to the US government in the
Middle East.” Please quantify the amount of  the previously reserved Libya related project
receivable. Please also confirm whether that amount and the amount of the previously
reserved receivable which was discus sed in your Professional Technical Services
segment in total approximated the $6.8 million disclosed in your Schedule II: Valuation
and Qualifying Accounts disclosure on page 118.  Finally, please provide an explanation
that fully describes why the decreas e in services provided to the US Government in the
Middle East had such a disproportionate impact on segment gross margin percentage
which increased from prior year’s 5.9% to 9.7% as of September 30, 2014. Please
provide us with a revised draft of the disc losure that you intend to include in your next
Form 10 -K. Please refer to Item 303(a)(3) of Regulation S -K and Section 501.12.b. of the
Financial Reporting Codification for guidance.

Note 7 - Joint Ventures and Variable Interest Entities, page 85

3. Per our  comment letter dated March 11, 2014, we had requested that you update your
future filings to include (a) gross profit, (b) net income and (c) net income attributable to
AECOM as is required by Article 1 -02(bb)(l)(ii) of Regulation S -X. In your response
dated April 11, 2014, you disclose that “…. the operating income the Company discloses
in its Joint Ventures and Variable Interest Entity footnote equates to gross profit.”  You
further disclose that AECOM  will include clarifying disclosure in future From 10 -Q and
Form 10 -K filings, as follows:

“Total revenue of the unconsolidated joint ventures was $518.4  million and
$527.5  million for the three months ended December  31, 2013 and 2012, respectively.
Total gross profit  operating income , which also materially equates to net income , of the
unconsolidated joint ventures was $10.0  million and $11.7  million for the three months
ended December  31, 2013 and 2012, respectively.”

Mr. Kadenacy
AECOM
January 2 2, 2015
Page 3

We note that in your subsequent Forms 10 -Q filed for your first, second and third
quarter s for fiscal year 2014, the above referenced disclosure was made in your filings.
Given the absence of this clarifying information in your current Form 10 -K, please tell us
whether there may have been any material changes in your unconsolidated joint ventu res
and the way they operate such that gross profit no longer equates to operating income;
and whether that also may not materially equate to net income. If there have been no
changes, please update your disclosures in future filings to include similar cla rifying
language as has been done previously.

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 applicab le Exchange 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.

You may contact Ameen Hamady , Staff Accountant, at (202) 551 -3891, or in his
absence,  Al Pavot , at (202) 551 -3738  or me at (202) 551 -3355,  if you have questions regarding
comments on the financial statements and related matters.

Sincerely,

 /s/ Terence O ’Brien

Terence O’Brien
Accounting Branch Chief