SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

May 26, 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 April 20, 2009 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.

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 reviewed your response to our previo us comment in our le tter dated February 2,
2009 and appreciate the additional information you have provided.  However, it continues
to appear to us that you have not full y demonstrated how you determined it was
appropriate to aggregate the 25 operating units that comprise your Infrastructure Services
reportable segment.  Therefore, pl ease address the following items:
• Please clarify for us what measure or gr oup of measures is us ed by your CODM to
evaluate the economic performance of your operating segments.  In addition, please
provide us with an analysis of these measur es for each quarter in the past two fiscal
years as well as the most recent interim period with an explanation of how you have
considered the similarities and differences in these measures when determining it was appropriate to aggregat e your operating segments.
• Please further explain the statement containe d in your response le tter dated December
11, 2008 that, in determining that it was a ppropriate to aggregate the 25 operating

Mr. James H. Haddox
Quanta Services, Inc.
May 26, 2009 Page 2
segments into your Infrastructure Services  reportable segment, you concluded that the
economic characteristics will be similar over the long-term in the sense that they are
expected to vary.
• Tell us how the geographic lo cation of the operating units impacts the results of the
operating unit by addressing the location of each  unit, the impact that the difference
in local labor costs may have on your units and the impact of the region on your revenue stream.
• Provide us with a quantified discussion rega rding the degree to which your operating
units earn revenue across industry lines.  It  appears that each of your operating units
is concentrated in one predominant industry.
• Provide us with a more detailed explanati on of how your Company bids on contracts.
Tell us if the bidding is done at the operati ng unit level or at the corporate level.  If
the bidding is done at the operating unit leve l, tell us whether multiple operating units
may compete against each other for bids.  If the bidding is done at the corporate level,
please explain to us how the contracts are allocated to the operating units.
• Tell us how you account for revenues and e xpenses at the opera ting unit level if
support from one operating unit is lent to another.  For example, please explain
whether the revenue and costs remain with the original operating unit or transfers to
the unit which was borrowed from.
• Provide us with a more specific and compre hensive discussion regarding the degree
and frequency of the interchangeability of your  labor.  We note from your letter dated
April 20, 2009 that individuals can  be utilized on portions of work in other industries.
It therefore appears that th ere may be limits on the interchangeability of your labor
based on the skill sets of the individuals.
• Please provide to us your most recent organization chart.
• We note the reports you have provided to us.  Please tell us what level of detail is
provided to your boa rd of directors.

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