SecProbe.io

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<TYPE>LETTER
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Mail Stop 3561

November 1, 2005

William A. Sanger
Chief Executive Officer
Emergency Medical Services Corporation
6200 S. Syracuse Way
Greenwood Village, CO 80111

Re: 	Emergency Medical Services Corporation
Registration Statement on Form S-4
Filed October 11, 2005
File No. 333-128925

Dear Mr. Sanger:

      We have limited our review of your Form S-4 to matters
concerning your compliance with our comments on your Form S-1,
File
No. 333-127115.  All issues related to your Form S-1 must be
resolved
before we will consider a request for acceleration of the Form S-4
registration statement.

      As we have conducted only a limited review of your
registration
statement, we urge all persons who are by statute responsible for
the
adequacy and accuracy of the registration statement to be certain
that all information required pursuant to the Securities Act of
1933,
as amended, has been included.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in your filing to be certain that they
have provided all information investors require for an informed
decision.  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 the disclosures they have made.

      In the event the company requests acceleration of the
effective
date of the pending registration statement, it should furnish a
letter, at the time of such request, acknowledging that:

* should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* the action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the company from its full responsibility for the adequacy
and
accuracy of the disclosure in the filing; and
* the company may not assert the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any
person
under the federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in connection with your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities under the Securities Act of 1933 and the
Securities
Exchange Act of 1934 as they relate to the proposed public
offering
of the securities specified in the above registration statement.
We
will act on the request and, pursuant to delegated authority,
grant
acceleration of the effective date.

      Please contact Daniel Zimmerman, Staff Attorney, at (202)
551-
3367 with any questions.

Sincerely,

Larry Spirgel
Assistant Director

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