SecProbe.io

February 10, 2020
Benedict Stas
Chief Financial Officer
Evoqua Water Technologies Corp.
210 Sixth Avenue
Pittsburgh, PA 15222
Re:Evoqua Water Technologies Corp.
Form 10-K for the Fiscal Year Ended September 30, 2019
Filed November 25, 2019
Form 8-K furnished on February 4, 2020
File No. 001-38272
Dear Mr. Stas:
            We have reviewed your filings 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended September 30, 2019
Management's Discussion and Analysis of Financial Condition and Results of Operations, page
48
1.We note your disclosure of Adjusted EBITDA throughout the filing.  Please revise to
clearly disclose that Adjusted EBITDA is a non-GAAP measure.
Consolidated Financial Statements
Note 11. Debt, page 108
2.We note that the interest rates for your credit agreements are tied, in part, to
LIBOR. Please include a risk factor discussing how the expected discontinuation of
LIBOR could affect your liquidity and results operations.

 FirstName LastNameBenedict Stas
 Comapany NameEvoqua Water Technologies Corp.
 February 10, 2020 Page 2
 FirstName LastName
Benedict Stas
Evoqua Water Technologies Corp.
February 10, 2020
Page 2
Note 23. Business Segments, page 129
3.We note your disclosure on page 49 that you evaluate your segment operating results
based on income from operations and EBITDA.  If the chief operating decision maker
uses more than one measure of a segment's profit or loss, the reported measure shall be the
one that management believes is determined in accordance with the measurement
principles most consistent with those used in measuring the corresponding amount in your
consolidated financial statements.  Please revise to remove EBITDA from the segment
footnote.  Refer to ASC 280-10-50-28 and Item 10(e)(ii)(C) of Regulation S-K.
Form 8-K furnished on February 4, 2020
Exhibit 99.1, page 13
4.We note your disclosure of “Adjusted net income (loss).”  Please revise to provide a more
detailed quantitative reconciliation showing each adjustment and revise to separately
disclose the income tax effects and explain how it was determined.  Also, revise to
disclose how the measure provides useful information to an investor.  Refer to Item
10(e)(i)(B) and (C) of Regulation S-K and Question 102.11 of the Non-GAAP
Compliance and Disclosure Interpretations.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            You may contact Brittany Ebbertt, Senior Staff Accountant, at 202-551-3572 or Christine
Dietz, Senior Staff Accountant, at 202-551-3408 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology