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Correspondence Letter

 April 10, 2012

 John Cash

 Branch Chief

 Division of Corporation Finance

 United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, DC 20549

Re:
Quanta Services, Inc.

 Form 10-K
for the year ended December 31, 2011

 Filed February 29, 2012

File No. 1-13831

 Dear
Mr. Cash:

 We are providing the following responses to the comment letter dated March 27, 2012 from the staff (the
“Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) regarding the Form 10-K for the year ended December 31, 2011 (our “Form 10-K”) filed by Quanta Services, Inc. (the “Company” or
“Quanta”). The responses provided below are numbered to correspond to the Staff’s comments, which have been reproduced herein for ease of reference. Unless otherwise indicated, all page numbers in our responses refer to our Form 10-K.

 Form 10-K for the year ended December 31, 2011

 Notes to the Consolidated Financial Statements

 5. Goodwill and Other
Intangible Assets, page 97

1.
With a view towards future disclosure, please provide us with a specific and comprehensive discussion of the under lying reasons for and impact of your operating
unit reorganizations in fiscal 2011. In this regard, please discuss how the goodwill impairment testing for these units changed from 2010 to 2011. In addition, please clarify why the reorganization did not cause a reclassification of your segment
results in prior periods.

 Response:

 In response to the Staff’s request for a specific and comprehensive discussion of the underlying reasons for and impact of the Company’s operating unit reorganizations during the fiscal year
ended December 31, 2011, the Company respectfully advises the Staff that the Company

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 periodically re-evaluates its
strategies to better align the Company’s operations as business environments evolve. During 2011, numerous factors contributed to management’s decision to reorganize certain of the Company’s operating units, including executive
turnover at one operating unit, strategic customer initiatives, streamlining and improving the coordination of operations and planned acquisition and business development strategies. The intended impact of these strategies and efforts is to improve
operating unit performance through cost reductions and better positioning of the Company’s operations to capitalize on future spending by its customers.

 Regarding changes to the Company’s goodwill impairment testing as a result of its operating unit reorganizations, the Company respectfully advises the Staff that, as described on page 84 of the Form
10-K, Quanta has determined that its individual operating units represent reporting units for the purpose of assessing goodwill impairments. The reorganizations required a reallocation between operating units of the goodwill amount associated with
the transferred operations. The Company utilized a relative fair value allocation approach in accordance with the requirements of Accounting Standards Codification (ASC) 350-20-35-45 to reassign goodwill to the operating units affected. As a result
of the reorganizations of business lines between operating units, Quanta’s goodwill impairment testing calculations changed for the operating units affected by these reorganizations to include a revised comparison of the fair values of the
reorganized operating units with their revised carrying values. The fair value assumptions used in this analysis, which are described in more detail in the disclosures presented in Note 2 to the Company’s consolidated financial statements on
pages 84-86 of the Form 10-K, reflected management’s revised expectations of cash flow to be generated from the budgeted and forecasted operating results of the reorganized entities. During the period prior to the 2011 reorganizations and in
connection with the Company’s 2010 goodwill impairment test, there were no goodwill impairment indicators noted. The reorganizations also changed the internal division to which certain operating units and/or business lines report for management
purposes, resulting in a reclassification between divisions of the goodwill amount associated with those operations, which has been presented as a reclassification between Quanta’s internal divisions in the caption “operating unit
reorganizations” in the table presented on page 97 in Note 5 to the Company’s consolidated financial statements included in the Form 10-K.

 In response to the Staff’s request for clarification regarding why the reorganizations did not cause a reclassification of the Company’s segment results in prior periods, the Company
respectfully advises that results of operations for its operating units are specifically classified according to the type of work performed and presented in the corresponding reportable segment based on that classification. The reorganizations of
certain operating units and/or business lines between divisions had no impact on the types of work performed by these operating units and/or business lines for segment reporting purposes, and thus had no effect on the Company’s segment results
in the prior periods presented.

 To the extent applicable in future periods, Quanta will consider additional disclosure regarding the reasons
for and impact of its internal reorganizations.

 U.S. Securities and Exchange Commission

 April 10, 2012

 Page 3

 12. Employee Benefit Plans, page 111

2.
We note that there have been fluctuations in the amount of your contributions to each plan year over year. In future filings please provide a description of the
nature and effect of any significant changes that affect the comparability of your contributions. Please refer to ASC Topic 715-80-50-6.

 Response:

 Quanta acknowledges the Staff’s comment with respect to the Company’s
future filings. The Company respectfully notes that page 112 of the Form 10-K provides the following disclosure, which management intended to be responsive to ASC 715-80-50-6: “Changes in annual contribution levels to these plans will vary
because the number of union employees, the duration of their employment and the plans in which they participate will vary from period to period based on the number and location of projects that Quanta has ongoing at any given time and the need for
union resources in connection with those projects.” In future filings, the Company will provide updated or additional disclosure to address significant changes affecting the comparability of Quanta’s contributions.

3.
We also note that you have made contributions to multi-employer defined contribution plans and these contributions have increased year over year. In future filings
please provide a description of the nature and effect of any significant changes that affect the comparability of your contributions. Please refer to ASC Topic 715-80-50-11.

 Response:

 Quanta acknowledges the Staff’s comment with respect to the Company’s
future filings. Additional disclosures similar to the Company’s response to the Staff’s comment 2 above will be included in Quanta’s disclosures regarding contributions to multi-employer defined contribution plans.

14. Commitments and Contingencies, page 114

 Leases, page 115

4.
We note that you lease land, buildings and equipment under operating leases. Please tell us how you evaluated the requirements of ASC Topic 840-10-25-14. In this
regard, please explain whether these leases contain nonperformance related default covenants, material adverse change clauses, cross-default provisions or subjective default provisions, and if so, how you evaluated such covenants and provisions.

 Response:

In response to the Staff’s comment, the Company respectfully advises the Staff that Quanta’s process for evaluating the requirements of ASC
Topic 840-10-25-14 occurs first as part of its commercial review of all lease terms and conditions prior to executing a lease agreement, and

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 subsequently as part of Quanta’s
ongoing processes for ensuring that all material operating lease agreements, including default provisions falling within the scope of ASC Topic 840-10-25-14, are identified, evaluated, accounted for and disclosed in accordance with ASC 840-10-25.
Quanta’s established business practices and administrative policies with regard to material leasing arrangements are designed to establish standard terms and conditions to which the Company is willing to be bound, and to avoid other terms and
conditions, including certain types of default provisions, that would create unacceptable risks for or commercial constraints on Quanta’s operations, including limitations on the incurrence of additional indebtedness outside of the
Company’s commercial lending arrangements.

 The default provisions contained in Quanta’s operating lease agreements are considered
by management to be customary in a financing arrangement and of a nature that is related solely to Quanta’s operations. Other than as described below, the default provisions included in Quanta’s facility lease agreements and master
equipment lease agreements are limited to matters involving nonperformance by the lessee, bankruptcy or declarations of insolvency by the lessee, requirements to maintain insurance coverage, dissolution or termination of existence of the lessee and
breaches of representations and warranties regarding the lessee’s ability to enter into the lease contract in good faith. As is typical in such contracts, Quanta’s facility lease agreements do not contain material adverse change clauses,
cross-default provisions or any other subjective default provisions. Certain of Quanta’s master equipment lease agreements do contain cross-default provisions that are tied to agreements with the same lessor. However, management considers such
terms to be customary and of a remote risk, as the Company has not entered into multiple master leasing arrangements with the same lessor.

 In
connection with the Company’s review of the default provisions included within its lease agreements, the Company considered the requirements set forth in ASC 840-10-25-14, noting that all required conditions were satisfied (except as described
below), resulting in no impact on the classification of Quanta’s leases.

 With regard to one specific master equipment lease agreement,
Quanta is subject to a material adverse change clause. This clause is limited to circumstances in which Quanta’s ability to perform its obligations under the agreement is impaired. Quanta evaluated this specific provision within the context of
applying ASC 840-10-25-14 and included the maximum amount that Quanta could be required to pay upon such an event of default in its calculation of minimum lease payments for purposes of applying paragraph 840-10-25-1(d), and such consideration did
not have any impact on the classification of this agreement as an operating lease.

 Litigation and Claims, page 115

5.
Your disclosure indicates that you are unable to estimate the amount of a possible loss or range of loss relating to both the California Fire Litigation and
California Fire Claim matters. We have the following comments related to this disclosure:

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 April 10, 2012

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•

 Please provide us with a specific and comprehensive discussion regarding why you cannot estimate your reasonably possible loss or range of loss in
excess of amounts accrued for each matter. We remind you that ASC 450 does not require estimation with confidence or precision.

•

 If you conclude that you cannot estimate the reasonably possible loss or range of loss please: (1) explain to us the procedures you undertake
on a quarterly basis to attempt to develop an estimate disclosure and (2) what specific factors are causing the inability to estimate and when you expect those factors to be alleviated. We recognize that there are a number of uncertainties and
potential outcomes associated with loss contingencies. Nonetheless, an effort should be made to develop estimates for purposes of disclosures, including determining which of the potential outcomes are reasonably possible and what the reasonably
possible range of losses would be for those reasonably possible outcomes.

•

 Please clarify if the amount the USDA may seek for past and future restoration and other damages could exceed $51.3 million.

•

 Future disclosures regarding reasonably possible losses in excess of amounts accrued may be provided on an aggregated basis.

 Response:

 As disclosed in the Form 10-K, with respect to lawsuits, claims and proceedings, the Company records a reserve when it is probable that a liability has been incurred and the amount of loss can be
reasonably estimated. In addition, the Company discloses matters for which management believes a material loss is at least reasonably possible. As noted in the Staff’s comment, with respect to the two referenced matters specifically disclosed
in the Form 10-K, the Company is currently unable to estimate the possible loss or range of possible losses in excess of applicable insurance coverage. Management reached this conclusion taking a number of factors into account, including:

•

 unspecified, unsubstantiated or indeterminate damages, including uncertainty with respect to the total damages that could be claimed and the claimed
allocation of responsibility for total damages;

•

 the availability of insurance and/or recourse against other parties, particularly in light of the litigation over whether insurance coverage exists in
respect of the California Fire Litigation;

•

 the early stage of proceedings, lack of discovery and incomplete factual record;

•

 uncertainties regarding the legal theories upon which claims have been brought and the defenses available to the Company;

•

 the number of parties involved, either in the referenced matter or in related litigation;

•

 the possibility of settlements prior to trial; and

•

 the likelihood of success at trial and the likelihood of success on appeal.

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 April 10, 2012

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 The Company respectfully notes, in particular, that no litigation has been filed in connection with the California Fire Claim, and that only very preliminary discovery has occurred in the various matters
related to the California Fire Litigation. In addition, in the California Fire Litigation, the plaintiff has not made a claim for specific damages.

 In accordance with the procedures discussed below, the Company will continue to monitor developments on these matters and reassess whether it is able to estimate the possible loss or range of possible
losses in excess of applicable insurance coverage. However, due to the inherent unpredictability of such developments, the Company is currently unable to estimate when the factors discussed above will be alleviated.

With regard to the Staff’s comment regarding the Company’s quarterly procedures to develop estimate disclosure, the Company respectfully
advises the Staff that it undertakes a quarterly review process during which all current lawsuits, claims and proceedings in which the Company is involved are analyzed, taking into account the guidance of ASC Topic 450. During this process,
management confers with in-house and outside counsel to discuss the current status of all such matters, including with respect to procedural posture, factual issues, legal theories, substantive rulings and claimed damages. Following that discussion,
management meets internally to discuss the matters, and to determine whether accruals are required for each matter if the potential loss is determined to be probable and the amount of loss can be reasonably estimated and, if applicable, whether any
change to prior accruals is required for any matter based on new information. Management also considers w