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CORRESP
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CORRESP

 June 30, 2014

 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, 2013

Filed March 3, 2014

Definitive Proxy Statement on Schedule 14A

Filed April 10, 2014

 Form
10-Q for the quarter ended March 31, 2014

 Filed May 8, 2014

File No. 1-13831

 Dear Mr. Cash:

We are providing the following responses to the comment letter dated June 3, 2014 from the staff (the “Staff”) of the U.S.
Securities and Exchange Commission (the “Commission”) regarding the above-referenced filings 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.

 Form 10-K for the Fiscal Year Ended December 31, 2013

 Management’s Discussion and Analysis of Financial Condition and Results of Operations, page 38

Segment Results, page 47

1.
We note that you do not quantify the impact of the various factors that affected your revenues from period to period. For example, on page 47, you state that the Electrical Power and Infrastructure Services revenues
were negatively impacted by lower revenues related to renewable energy projects, but you do not quantify the impact. Similarly, you do not quantify the impact of the increase in pipeline projects in the Oil and Gas Infrastructure Services segment.
These are just examples. In future filings please quantify the effects of such factors and also discuss whether you believe these factors are the result of a trend, and, if so, whether you expect it to continue and how it may impact your financial
condition and results of operations. Please also discuss the impact of individual material projects, as appropriate. See Item 303 of Regulation S-K and SEC Release No. 33-8350. Please supplementally show us what your revised
disclosure will look like in future filings.

 U.S. Securities and Exchange Commission

Page 2

 Response:

The Company advises the Staff that it will include quantitative disclosure in its future filings relating to factors affecting revenues from
period to period to the extent information is reasonably available to support precise, reliable quantitative disclosures.

 The Company
advises the Staff that its financial information systems and processes have been designed to provide reliable quantitative disclosure at the reporting segment level, which is the level at which the enterprise is managed. Although the Company’s
financial information systems provide management the ability to review individual projects, supplemental data categorizing projects into various customer or project attributes within segments (e.g., projects related to unconventional shale plays or
renewable energy) is not regularly reviewed or scrutinized by management, is not subject to the specific requirements of disclosure controls and procedures, and accordingly in substantially all cases is not sufficiently reliable to enable precise
quantification for disclosure purposes. Even when management can identify one or more specific projects having common attributes, the Company generally cannot categorize projects into sub-segment attributes to derive specific and precise
segment-wide or Company-wide results with the certainty it expects for its filings with the Commission due to the absence of disclosure controls and procedures for such categorizations. Providing precise and reliable quantitative disclosure with
respect to a multitude of sub-categories within each of the Company’s segments would require substantial time and effort on the part of management to design and implement processes and controls around such information, which information is not
ultimately needed or used to manage the Company’s business.

 The Company acknowledges the Staff’s request to quantify the impact
of the increase in pipeline projects in the Oil and Gas Infrastructure Services segment relating to unconventional shale development and the impact of the decrease in Electric Power Infrastructure Services segment revenues related to renewable
energy projects. The Company notes that it has included in the discussion referenced by the Staff supplemental qualitative and directional discussion with respect to such sub-segment categories as part of its comprehensive disclosure based on
management’s knowledge of customer feedback, resource deployment, industry trends and specific project knowledge. The Company respectfully submits, however, that quantifiable data with respect to these sub-segment categories is not used by
senior management to conduct the Company’s business and has not historically been captured within the Company’s financial information systems in a fashion that would support precise, reliable quantitative disclosures. For example, with
respect to renewable energy projects, management is able to identify specific projects that have experienced a decline in revenue from period to period. Coupled with management’s understanding of industry trends and circumstances, such as the
change in tax incentives with respect to renewable projects generally, the Company believes it is helpful to an investor’s understanding of its results of operations to provide qualitative and directional disclosure with respect to such period
to period changes. However, the Company’s disclosure controls and procedures do not operate and are not reviewed in a way that supports identifying all projects that may be categorized as renewable energy, and therefore the Company is not able
to provide precise, reliable quantitative disclosure at this sub-category level.

 U.S. Securities and Exchange Commission

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 3

 In response to the Staff’s request that the Company also discuss whether it believes
these factors are the result of a trend and, if so, whether such trends are expected to continue and how such trends may impact the Company’s financial condition and results of operations, the Company advises the Staff that such discussion is
provided as part of management’s forward-looking disclosures in the Outlook section of Management’s Discussion and Analysis of Financial Condition and Results of Operations, beginning on page 66 of the Form 10-K for the year ended
December 31, 2013 and page 55 of the Form 10-Q for the quarter ended March 31, 2014.

 The Company confirms to the Staff that, to
the extent the status of individual contracts or events 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 similar to
the revised disclosure above. The Company advises the Staff, however, that historically the Company has had few customers that accounted for more than 10% of the Company’s revenues within a period, and revenues from such customers were
typically derived from multiple separate and distinct contracts or projects.

 For the reasons discussed above, the Company respectfully
submits that the revised disclosure requested by the Staff as supplemental information would not be appropriate.

 Definitive Proxy Statement filed
April 10, 2014

 Compensation Discussion and Analysis, page 24

2013 Grants of Plan-Based Awards Table, page 51

2.
We note that the information disclosed under the heading “Estimated Possible Payments Under Equity Incentive Plan Awards” in the Grants of Plan-Based Awards table does not match the disclosure on page 36
regarding the Supplemental Incentive Plan. For example, the target payout for each of the named executive officers is significantly higher on page 36 than what is disclosed as the target payout on page 51. In addition, the grant date fair value of
the awards made under the Supplemental Incentive Plan as disclosed in the Grants of Plan-Based Awards Table is higher than the maximum payout listed. Please advise as to the inconsistencies in the disclosure. In addition, in future filings, please
discuss the reasons for any significant increases in SIP Target Incentive awards year-over-year, such as that that occurred from 2012 to 2013.

To facilitate the Staff’s review of the Company’s response to this comment, the Company will respond in turn to each of the
questions raised.

•

We note that the information disclosed under the heading “Estimated Possible Payments Under Equity Incentive Plan Awards” in the Grants of Plan-Based Awards table does not match the disclosure on
page 36 regarding the Supplemental Incentive Plan. For example, the target payout for each of the named executive officers is significantly higher on page 36 than what is disclosed as the target payout on page 51.

 U.S. Securities and Exchange Commission

 Page
 4

 Response:

The Company advises the Staff that the discrepancies between the target incentive amounts reflected on pages 36 and 51 of the Definitive Proxy
Statement filed April 10, 2014 (“2014 Proxy Statement”) are attributable to such disclosures referencing target incentive amounts for different performance years. As required by Item 402(b) of Regulation S-K, the Compensation
Discussion and Analysis (“CD&A”) in the 2014 Proxy Statement generally focus on compensation earned, paid and awarded in fiscal year 2013. However, for equity-based compensation, consistent with the Staff’s guidance beginning on
page 23 of SEC Release No. 33-9089, the 2013 compensation tables in the 2014 Proxy Statement reflect compensation granted during fiscal year 2013.

Generally, equity-based awards granted to the Company’s named executive officers (“NEOs”) during fiscal year 2013 were in
payment of incentive amounts earned during the 2012 performance year pursuant to the 2012 Supplemental Incentive Plan (the “2012 SIP”), and as disclosed in FN (2) of the 2013 Grants of Plan-Based Awards Table on page 51 of the 2014
Proxy Statement, the amounts shown under the “Estimated Possible Payments Under Equity Incentive Plan Awards” heading reflect the threshold, target and maximum incentive amounts that could have been granted during fiscal year 2013
pursuant to the 2012 SIP. These incentive amounts were also disclosed in the CD&A on page 33 of Quanta’s Definitive Proxy Statement filed April 12, 2013 (the “2013 Proxy Statement”).

In contrast, the CD&A in Quanta’s 2014 Proxy Statement disclosed, beginning on page 36, the threshold, target and maximum incentive
amounts that could have been earned during the 2013 performance year, as well as detailed disclosure about the performance levels achieved and the resulting incentive amounts actually earned during the 2013 performance year. Any equity-based awards
associated with these incentive amounts will appear in the 2014 Grants of Plan-Based Awards Table in Quanta’s proxy statement covering the 2014 fiscal year.

•

In addition, the grant date fair value of the awards made under the Supplemental Incentive Plan as disclosed in the Grants of Plan-Based Awards Table is higher than the maximum payout listed. Please advise as to the
inconsistencies in the disclosure.

 Response:

The Company respectfully advises the Staff that two factors contributed to the grant date fair value of the RSU awards granted being greater
than the maximum incentive amounts that could have been earned, as disclosed in the 2013 Grants of Plan-Based Awards Table. The first factor is the adjustment applied to equity-based awards granted pursuant to the 2012 SIP. As disclosed in the 2013
Proxy Statement, Quanta’s Compensation Committee applied a 110% multiplier to all incentive amounts earned under the 2012 SIP that were paid with an equity-based award rather than cash, which was intended to offset the risk and liquidity
discounts of equity-based awards relative to cash awards. The equity-based awards granted to NEOs during fiscal year 2013 were increased by this multiplier. Please see page 34 of the 2013 Proxy Statement, along with FN (a) to the ROE Component
Table on page 34 of the 2013 Proxy Statement and FN (a) to the Strategic Goal Component Table on page 36 of the 2013 Proxy Statement.

 U.S. Securities and Exchange Commission

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 5

 The second contributing factor is the difference between (1) the value assigned to the
underlying common stock for purposes of calculating of the number of RSUs required to satisfy the incentive amounts earned by each NEO, and (2) the value assigned to the underlying common stock for purposes of reporting the grant date fair
value of the RSU awards pursuant to ASC 718-20. As disclosed in FN (4) to the 2013 Grants of Plan-Based Awards Table on page 51 of the 2014 Proxy Statement, the Company’s calculation of the number of RSUs awarded to each NEO is based on
the average closing price of the Company’s common stock for the 20 consecutive trading days immediately preceding the date of grant, whereas the aggregate grant date fair value required to be reported for those same awards pursuant to ASC
718-20 is based on the closing price of the Company’s common stock on the date of the grant. The Company notes that when the incentive amount earned by an NEO is calculated based on a payout percentage at or near the maximum incentive amount,
due to strong Company performance, and the grant date closing price exceeds the 20-day average closing price, the grant date fair value of the RSU award may be greater than the maximum incentive amount that could have been earned.

As an illustration of the above factors, the grant date fair value of the RSUs granted to James F. O’Neil III on March 8, 2013 was
calculated as follows: Mr. O’Neil’s total incentive amount earned, as determined under the 2012 SIP, was $2,655,000, comprised of his ROE Component ($1,800,000) and his Strategic Goal Component ($855,000), as disclosed on pages 34-36
of the 2013 Proxy Statement. Because the incentive amount earned by Mr. O’Neil was satisfied with an equity-based award, the 110% multiplier was applied, thereby increasing Mr. O’Neil’s total incentive amount earned to
$2,920,500. The number of RSUs granted to Mr. O’Neil was then calculated by dividing Mr. O’Neil’s total incentive amount earned by the 20-day average closing price of the Company’s common stock prior to the grant date
($28.57), resulting in Mr. O’Neil being granted 102,223 RSUs on March 8, 2013. The grant date fair value of those RSUs was then calculated based on the closing price of Quanta’s common stock on the date of grant ($29.49) for an
aggregate grant date fair value of $3,014,556.

 Additionally, as indicated on page 40 of the 2013 Proxy Statement and page 33 of the 2014
Proxy Statement, the Company advises the Staff that for the 2013 performance year Quanta’s Compensation Committee has eliminated the 110% multiplier formerly used to adjust equity-based awards to their cash award equivalent. To the extent that
any such multiplier is utilized in the future, the Company will provide appropriate disclosure.

•

In addition, in future filings, please discuss the reasons for any significant increases in SIP Target Incentive awards year-over-year, such as that occurred from 2012 to 2013.

Response:

 The Company advises the Staff
that, to the extent there are significant year-over-year increases in target incentive levels in the future, the Company will include a discussion of the reasons for such increases in future filings.

Form 10-Q for the quarter ended March 31, 2014

Item 1 – Financial Statements

 U.S. Securities and Exchange Commission

 Page
 6

 Note 10 – Commitments and Contingencies, page 26

Collective Bargaining Agreements, page 31

3.
We note the disclosures you provide regarding the partial withdrawal liability you recorded related to the Central States Plan, including the fact that you increased your estimated withdrawal liability during the
period ended March 31, 2014. Since you disclose revised withdrawal estimates provided by the Central States Plan but did not