SecProbe.io

Mail Stop 4631

May 24 , 2017

Via E -mail
Ms. Jenny L. Apker
Chief Financial  Officer
Babcock & Wilcox Enterprises, Inc.
13024 Ballantyne Corporate Place
Suite 700
Charlotte, North Carolina 28277

Re: Babcock & Wilcox Enterprises, Inc.
 Form 10-K for the Year Ended December 31, 2016
Filed February 28, 2017
Form 10 -Q for the Period Ended March 31, 2017
Filed May 9, 2017
Response dated May 10, 2017
File No. 1 -36876

Dear Ms. Apker :

We have reviewed your response letter dated May 10, 2017 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 busines s days by providing the requested
information, or by advising us when you will provide the requested response.  If you do not
believe our comment  appli es to your facts and circumstances, please tell us why in your
response.

After reviewing the informatio n you provide in response to these  comment s, we may
have additional comments.

Form 10 -K for the Year Ended December  31, 2016

Goodwill and Long -Lived Asset Impairment, page 47

1. We note your response to comment 5  of our letter dated April 28, 2017 .   You determined
it was not more likely than not that the Renewable segment’s goodwill was impaired as
the fair value exceeded its carrying value by $114 million.  You note that your estimate
of fair value was based on your updated forecast which reflects the expectation that the

Ms. Jenny L. Apker
Babcock & Wilcox Enterprises, Inc.
May 24 , 2017
Page 2

 Renewable business will return to profitability.  Please help us better understand your
basis for assuming that the Renewable business will return to profitability, including
when you expect this to occur.  Please specifically addr ess the factors that led to this
expectation.  In this regard, we note that your disclosures on page 28 of your Form 10 -Q
for the period ended March 31, 2017 indicate a declining trend in terms of bookings and
backlog.

Form 10 -Q for the Period Ended Mar ch 31, 2017

Note 5 – Contracts and Revenue Recognition, page 10

2. Please expand your disclosures to explain why the $2.6 million reduction in the reserve
for estimated losses had no net impact on your statement of operations during the period
ended March 31, 2017.

Liquidity and Capital Resources, page 31

3. We note your response to comment 2  of our letter dated April 28, 2017 .  You expect cash
and cash equivalents, cash flows from operations, and your borrowing capacity to be
sufficient to meet your liquid ity needs.  You also expect your operations to use cash over
the full year of 2017 which is expected to be funded in part through borrowings from
your United States revolving credit facility.  We continue to believe that you should
expand your disclosures to better address how you determined that your current sources
of cash will be sufficient to meet your cash requirements over the next 12 months in light
of the following  specifically related to the three primary sources of cash you identified :
 Your cash a nd cash equivalents decreased from $365.2 million at December 31, 2015
to $95.9 million at December 31, 2016.  Your cash and cash equivalents further
decreased to $46.3 million at March 31, 2017 of which $35.5 million is held by
foreign entities;
 Your net cash generated from operating activities decreased significantly from $170.4
million during the year ended December 31, 2015 to $2.3 million during the year
ended December 31, 2016.  For the three months ended March 31, 2017, your net
cash used in operatin g activities increased from $37.9 million for the three months
ended March 31, 2016 to $74.8 million for the three months ended March 31, 2017;
and
 You had $228.8 million available borrowing capacity under your credit agreement at
December 31, 2016 compare d to $373 million at December 31, 2015.  This available
borrowing capacity was further significantly reduced to $55.1 million at March 31,
2017.
Refer to Item 303(a)(1) and (2) of Regulation S -K.

We remind you that the company and its management are re sponsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Ms. Jenny L. Apker
Babcock & Wilcox Enterprises, Inc.
May 24 , 2017
Page 3

 If you have any questions regarding these comments, please direct them to Nudrat Salik,
Staff Accountant, at (2 02) 551 -3692 or, in her absence, me at (202) 551 -3854 .

 Sincerely,

/s/ Melissa N. Rocha

Melissa N. Rocha
      Senior Assistant Chief Accountant
Office of Manufacturing and Construction