SecProbe.io

April 26, 2013

Via facsimile
Mr. Derrick A. Jensen , Chief Financial Officer
Quanta Services, Inc.
2800 Post Oak Blvd., Suite 2600
Houston, TX  77056

Re: Quanta Services, Inc.
 Form 10-K for the year ended December 31, 201 2
Filed March 1, 2013
File No. 1 -13831

Dear Mr. Jensen :

We have reviewed your filing an d 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 advising us when you will provide the requested response.  If you do not
believe our comments apply to your facts and circums tances please  tell us why in your response.

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

General

1. Where a comment below requests additional disclosures or other revisions in fu ture
filings, please show us your proposed revisions in your supplemental response.  Please
include the revisions in future filings, including interim filings, if applicable.

Business
Backlog, page 7
2. We note that backlog is not a measure defined by general ly accepted accoun ting
principles and that your methodology for determining backlog may not b e comparable to
the methodologies used by other comp anies.  In future filings , beginning with your next
quarterly report, please provide the following expa nded disc losures regarding backlog:
 An enhanced discussion of how your backlog is calculated, including what it
includes and what it excludes in regard to the following to the extent applicable,
firm orders, extensions/add -ons, pass -through costs, funded/unfunded a mounts,

Mr. Derrick A. Jensen
Quanta Services, Inc.
April 26 , 201 3
Page 2

 and VIE/joint venture contracts versus company contracts.  Specifically disclose
the amount of backlog related to your estimate s for MSAs and renewal options.
 If relevant, discuss any material changes in the methodology used to determine
backlog i n each period.
 To allow better insight into changes in your backlog from period to period, provide
a roll -forward of your backlog.  The roll -forward should include current period
beginning and ending balances, current period additions, cancellations, and
amounts recognized in revenue, as well as any other major categories relevant to
your facts and circumstances.
 To the extent any of your backlog is not moving forward, quantify and discuss
such amounts.
 If material, disclose the amount of backlog related to uncompleted projects in
whic h a loss provision is recorded.
 Address and discuss expected margins and margin trends in your backlog.
 Provide a breakdown of backlog by service line and/or contract type.

Management’s Discussion and Analysis of Financial Condition and Results of Operations, page
36
Results of Operations, page 41

3. Please revise MD&A in future annual and quarterly filings to address the following:
 Quantify the factors you identify as impacting consolidated and segment revenues
from period to  period and more fully explain the reasons for increases and
decreases in the number and size of projects.  Disclose the number of projects and
the average size of projects during each period and more fully explain the reasons
for changes.
 To the extent ma terial, consider disclosing and discussing the impact and status of
significant projects.
 More fully explain the reasons for contract losses, including the facts and
circumstances that lead to the losses, the amount of loss you recorded, the current
statu s of loss projects (including the percent complete and the remaining amounts
in backlog), the expected timeframe for completion, and the amount of any
reasonably possible additional losses.
 During the most recent year, we noted a higher increase in total a ccounts
receivable and costs and estimated earnings in excess of billings on uncompleted
contracts relative to the increase in revenues.  Please disclose and discuss the
factors that lead to such changes relative to the change in revenues and consider
disclosing and discussing changes in days outstanding and/or your cash conversion
cycle during each period presented.
 During the most recent year, we noted a significant increase in claims and change
orders.  Please disclose and discuss the principle items inc luded in such amounts,
including: the specific nature , segment  impacted;  your basis for determining
amounts are probable and estimable; current status , and the expected timeframe for
resolution.

Mr. Derrick A. Jensen
Quanta Services, Inc.
April 26 , 201 3
Page 3

Critical Accounting Policies
Self-Insurance, page 57

4. Please  revise future filings to disclose the amounts expensed during each period
presented.

Valuation of Goodwill, page 57

5. Please revise future filings to address the following:
 Clarify the number of reporting units you have and test for impairment and clarify
how your reporting units relate to your reportable segments,
 Clarify which, if any, of your reporting units are evaluated on a qualitative basis,
and
 Clarify the nature of and reasons for the operating unit  reorganizations, disclosed
in Note 6 on page 99.

Consolidated Financial Statements

Report of Independent Registered Public Accounting Firm, page 74

6. It is not clear to us why the current auditors’ report does not refer to the consolidated
statements of comprehensive income.  Please advise or revise.

Note  2.  Summary of Signific ant Accounting Policies, page 82

7. If applicable, please revise future filings to disclose the amount of progress payments
netted against contract costs as well as the amount of advances that are payments on
account of work in pr ogress as of each balance sheet date.   Refer to ASC 910 -20-50-1(b),
Rule 5 -02.6(d)(iii) of Regulation S -X, and ASC 910 -405-50-2.

8. Please revise future filings to disclose the nature and status of the principle items
included in claims and change orders.  Refer to Rule 5 -02.3(c)(3) of Regulation S -X,
ASC 910 -310-50-1, and ASC 910 -20-50-1a.

9. Please revise future filings to disclose your policy for and amounts of pre -contract costs
deferred, if material.  Refer to ASC 910 -340-50-1.

10. Please revise future filings  to disclose the effects of material revisions in contract
estimates.   Refer to ASC 605 -35-50-9.

11. In regard to the change in your ownership interest in HEP, please tell us the amount of
any gain or loss you recorded and explain how the amount was determined .

Mr. Derrick A. Jensen
Quanta Services, Inc.
April 26 , 201 3
Page 4

 Note 13.  Employee Benefit Plans, page 112

12. Please more fully explain to us the specific factors resulting in your inability to estimate
additional funds you may be required to contribute to under -funded multi -employer
pension plans.

Note 15.  Commitments and Contingencies, page 114

13. If applicable, please revise future filings to disclose the amount of liquidating damages
you may be subject to, including the amount accrued at each balance sheet date and the
amount or range of reasonably possible  additional losses.

Note 16.  Segment Information, page 122

14. Please revise future filings to disclose revenues by service line.  Refer to ASC 280 -10-50-
40.  We note your references to various service lines, particularly in the Electric Power
segment.

We u rge 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 applica ble 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 t he 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 Mindy Hooker  at (202) 551 -3732, Anne McConnell  at (202) 551 -3709
or me at (202) 551 -3768  with any questions.

Sincerely,

 /s/ John Cash

John Cash
Branch Chief