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Correspondence

 May 31, 2013

 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, 2012

Filed March 1, 2013

File No. 1-13831

 Dear Mr. Cash:

 We are providing the following responses to the comment letter dated April 26, 2013 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, 2012 (the “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 the Form 10-K.

 General

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

 Response:

Where a comment below requests that additional disclosures or other revisions be made, we have included a draft of such additional disclosures or other
revisions, to the extent applicable, within our responses. We will also include such additional disclosures or other revisions in our future filings, including interim filings, if applicable, consistent with the responses outlined below.

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 Business

 Backlog, page 7

2.
We note that backlog is not a measure defined by generally accepted accounting principles and that your methodology for determining backlog may not be comparable to
the methodologies used by other companies. In future filings, beginning with your next quarterly report, please provide the following expanded disclosures 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 amounts, and VIE/joint venture contracts versus company contracts. Specifically disclose the amount of backlog related to your estimates for MSAs and renewal
options.

 Response:

 The Company acknowledges the Staff’s comment and advises the Staff that in future filings the Company intends to provide an enhanced discussion of its calculation of backlog. The following is a draft
of the Company’s planned disclosure:

 Backlog

Backlog is not a term recognized under United States generally accepted accounting principles; however, it is a common measurement used in
our industry. Our methodology for determining backlog may not be comparable to the methodologies used by other companies.

 Our
backlog represents the amount of consolidated revenue that we expect to realize from future work under construction contracts and long-term maintenance contracts, or master service agreements (MSAs). These estimates include revenues from the
remaining portion of firm orders not yet completed and on which work has not yet begun, as well as revenues from change orders, renewal options, and funded and unfunded portions of government contracts to the extent that they are reasonably expected
to occur. For purposes of calculating backlog, we include 100% of estimated revenues attributable to consolidated joint ventures and VIEs. The following tables present our total backlog by reportable segment as of
                     and
                    , along with an estimate of the backlog amounts expected to be realized within 12 months of each balance sheet date (in
thousands):

 [table]

 Revenue estimates included in our backlog can be subject to change as a result of project accelerations, cancellations or delays due to various factors, including but not limited to commercial issues,
regulatory requirements and adverse weather. These factors can also cause revenue amounts to be realized in periods and at levels different than originally projected. Generally, our customers are not contractually committed to specific volumes of
services under our MSAs, and while we did not experience any material cancellations during the current period, most of our contracts may be terminated, typically upon 30 to 90 days notice, even if we are not in default under the contract. We
determine the estimated amount of backlog for work under MSAs by using recurring historical trends inherent in current MSAs, factoring in seasonal demand and projected customer needs based upon

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ongoing communications with the customer. In addition, many of our MSAs, as well as contracts for fiber optic licensing, are subject to renewal options. As of
                     and
                    , MSAs accounted for approximately     % and     %, respectively, of
our estimated total backlog. There can be no assurance as to our customers’ requirements or that our estimates are accurate.

 The Company
advises the Staff that as of December 31, 2012 and 2011, MSAs accounted for approximately 45% and 43%, respectively, of the Company’s total backlog. The Company further advises the Staff that pass-through costs generally are not included
in the Company’s backlog estimates and that revenues associated with such costs, as well as from unfunded portions of government contracts, are not material.

•

 If relevant, discuss any material changes in the methodology used to determine backlog in each period.

Response:

 The Company acknowledges the
Staff’s comment and advises the Staff that, to the extent there are material changes in the Company’s methodology for determining backlog in the future, the Company will disclose such changes in its future filings.

•

 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.

Response:

 The Company advises the Staff
that it uses a “ground up” methodology for calculating backlog as of each reporting date. For each quarter the Company determines, on a contract-by-contract basis, as of the date of determination, the total amount of revenue expected to be
realized from work to be performed in the future on uncompleted contracts. Because it is not the Company’s practice to determine backlog by adjusting the prior period estimate for additions, cancellations, recognized amounts and other
circumstances, management does not track or evaluate the amount of backlog revenue added from one period to the next, the amount of revenue recognized during a period that was previously reported in backlog or the amount of previously reported
backlog that was cancelled during a period. The Company respectfully submits that, as a result of this “ground up” methodology, the data required to provide the requested backlog roll-forward information is not readily available, as the
Company’s information systems and financial control procedures are not designed to capture or provide the necessary underlying information. Additionally, the Company does not interpret Item 101(c)(1)(viii) of Regulation S-K to require
registrants to provide a roll-forward of backlog and the Company is not aware of any Staff guidance indicating such a requirement.

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•

 To the extent any of your backlog is not moving forward, quantify and discuss such amounts.

Response:

 The Company advises the Staff
that, as a result of the “ground up” methodology discussed above, if a contract included in prior-period backlog were no longer expected to move forward and contribute to the Company’s expected future revenues, that contract would no
longer be included in backlog. The Company further advises the Staff that to the extent that the Company becomes aware of material developments affecting the realization of backlog as a result of cancellations, the Company will provide appropriate
disclosure with respect to such developments as part of its backlog discussion.

•

 If material, disclose the amount of backlog related to uncompleted projects in which a loss provision is recorded.

 Response:

The Company acknowledges the Staff’s comment and advises the Staff that, to the extent material, the Company will disclose in future filings the
amount of backlog related to uncompleted projects in which a loss provision is recorded. As of December 31, 2012, the amount of backlog related to uncompleted projects in which a loss provision was recorded was not material.

•

 Address and discuss expected margins and margin trends in your backlog.

Response:

 The Company acknowledges the
Staff’s comment and respectfully notes that backlog is calculated based on the amount of gross revenue expected to be realized from its contracts. The Company regularly discloses general margin trends expected in its business, which statements
apply equally to backlog. Please see “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Outlook” on pages 62-66 of the Form 10-K.

•

 Provide a breakdown of backlog by service line and/or contract type.

Response:

 As stated in the proposed
revised backlog disclosure above, in future filings the Company intends to provide a breakdown of backlog by contract type (MSAs vs. non-MSAs). In response to the Staff’s request for additional disclosure of backlog by service line, the Company
respectfully refers the Staff to the Company’s response to Comment 14 below.

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 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 material, consider disclosing and discussing the impact and status of significant projects.

Response:

 The Company notes that, as
disclosed in the Form 10-K, revenues increased year over year primarily due to an increase in the number and size of electric and natural gas transmission projects as a result of overall increases in capital spending by its customers. The
quantitative impact of the increase in each segment is discussed in the segment-specific discussions under “Results of Operations” beginning on page 41 of the Form 10-K. For a discussion of the reasons for the changes in capital spending
of the Company’s customers, see “Management’s Discussion and Analysis of Financial Condition and Results of Operations—Outlook.”

 The Company currently has several thousand contracts with hundreds of customers covering a disparate range of service offerings spanning different industries. The Company’s historical disclosure with
respect to increases or decreases in the “number and size of projects” was intended to provide directional, qualitative commentary with respect to changes in customer spending patterns. Specific quantitative measures with regard to the
number and size of projects were not provided due to the underlying lack of comparability for such metrics from one period to the next. The Company notes that the absolute number of projects ongoing during a period may increase while overall
revenues during the same period may decrease, or vice versa. Similarly, the average size of projects, which is a mathematical function of those two values, may fluctuate in a manner not correlated with movements in revenue, gross margin or net
income. The Company respectfully submits that quantitative disclosure of the number or average size of projects during a period would not provide further clarification of the Company’s financial or operating performance.

The Company confirms to the Staff that, to the extent the status of individual contracts or projects would materially impact a financial statement
user’s understanding of the Company’s consolidated or segment revenues, it will include relevant disclosure in future filings.

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•

 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 status 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.

 Response:

The Company acknowledges the Staff’s comment and advises the Staff that, to the extent the Company has loss contracts in the future that materially
impact the Company’s financial condition or results of operations, it will provide disclosure with respect to such loss contracts, including the facts and circumstances that led to the losses, the amount of loss recorded, the current status
(including the percent complete and the remaining amounts in backlog), the expected timeframe for completion and, to the extent required by ASC 450, the amount of any reasonably possible additional losses.

•

 During the most recent year, we noted a higher increase in total accounts 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.

 Response:

The Company advises the Staff that consolidated revenues for the year ended December 31, 2012 increased $1.73 billion, or 41.2%, to $5.92 billion as
compared to revenues of $4.19 billion for the year ended December 31, 2011. Combined accounts receivable and costs and estimated earnings in excess of billings on uncompleted contracts at December 31, 2012 increased $0.52 billion, or
45.2%, to $1.67 billion as compared to $1.15 billion at December 31, 2011. Revenues for the year ended December 31, 2011 increased $1.18 billion, or 39.2%, as compared to revenues of $3.63 billion for the year ended December 31, 2010.
Combined accounts receivable and costs and estimated earnings in excess of billings on uncompleted contracts at December 31, 2011 increased $0.33 billion, or 40.7%, from approximately $0.81 billion at December 31, 2010.

The foregoing data demonstrates close correlation between the substantial growth rates from 2010 to 2012 in the Company’s revenues and the related
combined accounts receivable and costs and estimated earnings in excess of billings on uncompleted contracts balances. The Company agrees with the Staff that a correlation of such activity to the Company’s cash conversion cycle provides a
degree of further clarification with respect to the above described operating activity, and as disclosed on page 48 of the Form 10-K, the Company’s discussion of liquidity and capital resources included commentary regarding the decrease in
operating cash flow from continuing operations for 2012 as compared to 2011 and 2010 being primarily due to increased working capital requirements in 2012 as a result of the increase in the amount of work ongoing during the 2012 period, partially
offset by overall improved operating results.

 The slightly higher increase in 2012 in combined accounts receivable and costs and estimated
earnings in excess of billings