SEC Comment Letter for QUANTA SERVICES, INC. (PWR) (CIK 0001050915) (PWR) — Feb 6, 2009
QUANTA SERVICES, INC. (PWR) (CIK 0001050915)
Date: Feb. 6, 2009 · CIK: 0001050915 · Accession: 0000000000-09-006284
AI Filing Summary & Sentiment
Referenced dates: December 23, 2008, December 23, 2008
Letter
UNITED STATES SECURITIES AND EXCHANGE COMMISSION WASHINGTON, D.C. 20549-7010 DIVISION OF CORPORATION FINANCE February 6, 2009 Mr. James H. Haddox Chief Financial Officer, Quanta Services, Inc. 1360 Post Oak Blvd., Suite 2100 Houston, TX 77056 Re: Quanta Services, Inc. Form 10-K for the year ended December 31, 2007 Definitive Proxy Statement, April 18, 2008 Form 10-Q for the quarter ended September 30, 2008 File No. 1-13831
Dear Mr. Haddox: We have reviewed your response to our letter dated December 23, 2008 and have the following comment. We ask that you respond within ten business days.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requir ements 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 aspe ct of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Mr. James H. Haddox Quanta Services, Inc. February 6, 2009 Page 2
Form 10-Q for the period ended September 30, 2008
Notes to the Condensed Conso lidated Financial Statements Note 9. Segment Information, page 25
1. We have read your response to our commen t in our previous letter dated December 23, 2008 and appreciate the additional informati on you have provided. We note that you have aggregated 26 operating segments into your Infrastructure Services reporting segment. Paragraph 17 of SFAS 131 states th at two or more operating segments may be aggregated into a single operating segment if the aggregation is consistent with the objectives and basic principles of SFAS 131. As outlined in paragraph 3 of SFAS 131, segment disclosures are intended to help users of financial st atements better understand a company’s performance. Based on the inform ation you have presented in your response letters as well as the information contained in your periodic reports, it appears that your 26 operating segments do not all have simila r characteristics. For example, we note differences in your operating segments base d on the type of work performed and the industry in which the segments operate. Ther efore it appears that by aggregating all 26 operating segments into your Infrastructure Services reporting segment, you may not meet the basic principles and objective s of SFAS 131 since a more disaggregated approach would provide users with more specific information to assess your performance. Please reconsider your a pproach or tell us why you believe your aggregation policy complies with SFAS 131.
As appropriate, please amend your filing a nd respond to these comments within ten business days or tell us when you will provide us with a response. Please provide us with a supplemental response letter that keys your re sponses to our comments and provides any requested supplemental information. Detailed letter s greatly facilitate our review. Please file your supplemental response on EDGAR as a corres pondence file. Please understand that we may have additional comments after reviewing your responses to our comments. If you have any questions regarding this comm ent, please direct them to Mindy Hooker, Staff Accountant, at (202) 551-3732, Tricia Ar melin, Senior Staff A ccountant, at (202) 551- 3747, or to the undersigned at (202) 551-3768. Sincerely, John Cash Branch Chief
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010
DIVISION OF
CORPORATION FINANCE
February 6, 2009
Mr. James H. Haddox Chief Financial Officer, Quanta Services, Inc. 1360 Post Oak Blvd., Suite 2100 Houston, TX 77056
Re: Quanta Services, Inc.
Form 10-K for the year ended December 31, 2007 Definitive Proxy Statement, April 18, 2008 Form 10-Q for the quarter ended September 30, 2008
File No. 1-13831
Dear Mr. Haddox:
We have reviewed your response to our letter dated December 23, 2008 and have the
following comment. We ask that you respond within ten business days.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requir ements 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 aspe ct of our review. Feel free to call us at
the telephone numbers listed at the end of this letter.
Mr. James H. Haddox
Quanta Services, Inc.
February 6, 2009 Page 2
Form 10-Q for the period ended September 30, 2008
Notes to the Condensed Conso lidated Financial Statements
Note 9. Segment Information, page 25
1. We have read your response to our commen t in our previous letter dated December 23,
2008 and appreciate the additional informati on you have provided. We note that you
have aggregated 26 operating segments into your Infrastructure Services reporting
segment. Paragraph 17 of SFAS 131 states th at two or more operating segments may be
aggregated into a single operating segment if the aggregation is consistent with the
objectives and basic principles of SFAS 131. As outlined in paragraph 3 of SFAS 131,
segment disclosures are intended to help users of financial st atements better understand a
company’s performance. Based on the inform ation you have presented in your response
letters as well as the information contained in your periodic reports, it appears that your
26 operating segments do not all have simila r characteristics. For example, we note
differences in your operating segments base d on the type of work performed and the
industry in which the segments operate. Ther efore it appears that by aggregating all 26
operating segments into your Infrastructure Services reporting segment, you may not
meet the basic principles and objective s of SFAS 131 since a more disaggregated
approach would provide users with more specific information to assess your
performance. Please reconsider your a pproach or tell us why you believe your
aggregation policy complies with SFAS 131.
As appropriate, please amend your filing a nd respond to these comments within ten
business days or tell us when you will provide us with a response. Please provide us with a
supplemental response letter that keys your re sponses to our comments and provides any
requested supplemental information. Detailed letter s greatly facilitate our review. Please file
your supplemental response on EDGAR as a corres pondence file. Please understand that we
may have additional comments after reviewing your responses to our comments.
If you have any questions regarding this comm ent, please direct them to Mindy Hooker,
Staff Accountant, at (202) 551-3732, Tricia Ar melin, Senior Staff A ccountant, at (202) 551-
3747, or to the undersigned at (202) 551-3768.
Sincerely, John Cash Branch Chief