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CORRESP
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corresp

January 9, 2009

John Cash

Branch Chief

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549-7010

Mail Stop 3561

    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. Cash:

     We are providing the following response to the comment letter dated December 23, 2008 from the
staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) regarding the Form
10-Q for the quarter ended September 30, 2008 filed by Quanta Services, Inc. (the “Company” or
“Quanta”). The following response is keyed to the Staff’s comment. All page numbers in our
response refer to the respective page numbers in the relevant filing.

Form 10-Q for the period ended September 30, 2008

Notes to the Condensed Consolidated Financial Statements

Note 9. Segment Information, page 25

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    We have read your response to our previous comment eight of our letter dated November 26,
2008 and appreciate the additional information. In order to help us more clearly understand
your operating units and reportable segments, please provide us with the actual reports for
the fiscal year end December 31, 2007 and the year-to-date quarter ended September 30, 2008
which are reviewed by your chief operating decision maker. Such reports should be actual, and
provided at the lowest level of detail as provided to the CODM. Additionally, we note your
reference to the recent aggregation of certain measures by type of work and the fact that
certain presidents and vice-presidents have been named to oversee companies with similar
operations. Please further explain these changes and provide us with the actual reports for
these measures for the same periods noted above. We may have further comment.

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Response:

In response to the Staff’s comment, we have provided supplementally by hand delivery and under
separate cover, pursuant to a confidential treatment request under the Freedom of Information Act
and applicable regulations of the Commission, copies of (i) the actual reports for the fiscal year
ended December 31, 2007 and the year-to-date quarter ended September 30, 2008 that are reviewed by
Quanta’s CODM and represent the lowest level of detail as provided to the CODM and (ii) the actual
reports for revenues by type of work for the same periods noted above. We have also provided, as
additional information, the actual reports provided to Quanta’s CODM for the month ended July 31,
2008, which are representative of the reports reviewed by the CODM on a monthly basis.

The following provides a summary description of the various supplemental reports provided to assist
you in your review:

    •

    The reports labeled Category A, which are those provided to you in binders, include
financial information by operating unit for the fiscal year ended December 31, 2007, the
year-to-date quarter ended September 30, 2008 and the month ended July 31, 2008. These
reports include data for the month, quarter-to-date and year-to-date for the respective
periods. On certain reports, the operating unit information is sub-totaled by management
division (e.g. electric power), but that does not correspond to information by type of
work. The data presented by operating unit includes income statement, balance sheet, cash
flow, capital expenditure and backlog data, as well as detailed information by project.
Reports consistent with Category A reports are reviewed on a monthly basis by the CODM.

    •

    The reports labeled Category B include supplemental operating and financial data
reviewed by the CODM for the fiscal year ended December 31, 2007 and for the year-to-date
quarter ended September 30, 2008. These supplemental reports include data by operating
unit such as employee count, summaries by contract type and strategic alliances as well as
various summary comparisons of operating performance to forecasted and prior period
information. They also include the type of work data that we are providing separately as
Category C below. Reports consistent with Category B reports are only prepared and
provided for review by the CODM on a quarterly basis.

    •

    The reports labeled Category C provide revenue and gross margin data by type of work.
Reports consistent with Category C reports are also, like Category B, only prepared and
provided for review by the CODM on a quarterly basis.

Quanta’s CODM utilizes the monthly, quarterly and year-to-date data included in reports consistent
with those we have provided to you as the Category A reports, which provide key financial and
operating information at the operating unit level, to make decisions regarding the allocation of
resources, assessment of performance and management of risk. We believe that the information that
is provided consistently throughout all monthly periods is most indicative of the operating results
utilized by our CODM in his decision-making. The limited information in the Category B and C
reports is not sufficient to independently facilitate decision-making by our CODM.

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With regard to the Staff’s request for further explanation to our reference to recent changes for
the aggregation of certain data by type of work, these changes were made in order to conform the
presentation of information between Quanta and InfraSource Services, Inc. (“IFS”) following the
acquisition of IFS in August 2007. Prior to the acquisition of IFS, Quanta had historically
gathered and discussed revenues by type based on the customer’s industry rather than by the type of
work being performed. IFS, however, had been aggregating and disclosing revenues by type of work
being performed. Quanta management evaluated information for the purposes of combining the two
companies and concluded that disclosure of revenues by type of work may be more understandable by
investors, and therefore Quanta began to aggregate and disclose revenues by type of work beginning
with the third quarter of 2007, which was the first quarter subsequent to the IFS acquisition.

The reference that we made in our response to Comment 8 in our letter dated December 11, 2008 to
the fact that certain presidents and vice-presidents oversee companies with similar operations
relates to management for organizational purposes and not to any recent changes in Quanta’s
approach to analysis of financial information, and no changes have occurred within the management
structure of the organization as a result of the aggregation of revenue by type of work which began
in the third quarter of 2007. The reference to the various presidents and vice-presidents who
oversee certain operating units serves to recognize that these personnel exist in management
positions; however, they are not identified as Quanta’s CODMs as discussed in our response to
Comment 8 in our December 11, 2008 letter regarding criteria (b) of paragraph 10 of SFAS 131.

We respectfully request an opportunity to discuss this response letter further with the Staff if,
following a review of this information, the Staff does not concur with our views. If you have
further questions or comments, or if you require additional information, please do not hesitate to
contact the undersigned by telephone at (713) 985-6406 or by facsimile at (713) 629-7676.

    Very truly yours,

/s/ James H. Haddox

James H. Haddox

Chief Financial Officer

    cc:

    James R. Ball

    Chairman, Audit Committee

    David Carroway

    Assurance Partner

    PricewaterhouseCoopers LLP

    1201 Louisiana

    Suite 2900

    Houston, Texas 77002

    Mindy Hooker

    Tricia Armelin

    Division of Corporation Finance

    United States Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C. 20549-7010

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