SecProbe.io

January 23, 2013

Via E -mail
Mr. Evan L. Hart
Chief Financial Officer
Mueller Water Products, Inc.
1200 Abernathy Road, N.E., Suite 1200
Atlanta, GA  30328

Re: Mueller Water Products, Inc.
 Form 10 -K for the Fiscal Year Ended September 30, 2012
 Filed  November 29, 2012
 File No. 1-32892

Dear Mr. Hart:

We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information  so we may better understand your
disclosure.

Please respond to this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not
believe our comments apply to your f acts and circumstances, please  tell us why in your response.

After reviewing the information you provide in response to these comments, we may
have additional comments.

Form 10 -K for the Fiscal Year Ended September 30, 2012

Item 7. Manage ment’s Discussion and Analysis of Financial Condition and Results of
Operations, page 21

Results of Operations, page 22
Segment Analysis, page 23

1. In future filings, please expand your narrative to quantify the factors that you identify as
reasons for the  changes in your segment results from period -to-period.

Mr. Evan L. Hart
Mueller Water Products, Inc.
January 23, 2013
Page 2

Effect of Inflation; Seasonality, page 29

2. We note that Mueller Co. experienced a 3% decrease in average cost per ton of scrap
steel while Anvil experienced a 5% increase in average cost per ton of s crap steel
purchased in 2012 compared to 2011.  In future filings, please provide additional detail
on the factors impacting the cost of scrap steel and other raw materials for Mueller and
Anvil so that investors can understand why any apparent inconsisten cies exist.

Financial Statements

Note 18. Commitments and Contingencies, page F -32

3. Please tell us and revise future filings, to explain whether your assessment of materiality
concerning your Burlington, NJ environmental matter also extends specifically to your
cash flows.

Note 21. Consolidating Guarantor and Non -Guarantor Financial Information, page F -35

4. Please revise future annual and quarterly filings to disclose, if accurate, that each
guarantor subsidiary is “100% owned” by the parent company, as r equired by Rule 3 -
10(i)(8)(i) of Regulation S -X or, if not accurate, please explain to us how your condensed
consolidating financial statements comply with Rule 3 -10 of Regulation S -X.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applica ble Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a com pany’s disclosure, they are responsible for the accuracy
and adequacy of t he disclosures they have made.

 In responding to our comments, please provide a written statement from the company
acknowledging that:

 the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

 staff comments or changes to disclosure in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a def ense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

Mr. Evan L. Hart
Mueller Water Products, Inc.
January 23, 2013
Page 3

 You may contact Dale Welcome at (202) 551 -3865 or me at (202) 551 -3768  if you have
questions regarding comments on the financial state ments and related matters.  Please contact
Edward M. Kelly  at (202) 551 - 3728  or Pamela A. Long  at (202) 551 -3765  with any other
questions.

Sincerely,

/s/ John Cash

John Cash
Accounting Branch Chief