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April 12, 2005

Mr. John Cash
Accounting Branch Chief
Mail Stop 0510
Securities and Exchange Commission
450 Fifth Street N.W.

Washington, DC 20549

Re:  EMCOR Group, Inc.
     Form 10-K for the year ended December 31, 2004
     File No. 1-8267

Reference is made to your letter dated March 29, 2005 regarding the Form 10-K
(the "Form 10-K") of EMCOR Group, Inc. (the "Company") for the year ended
December 31, 2004.

I have set forth below the Company's response to the comments contained in your
letter and all appropriate requested supplemental information. The numbered
captioned paragraphs below correspond to the same numbered captioned comments in
your letter.

     1.   COMMISSION FILE NUMBER: In future filings the Company will use the
          current file number on the respective cover pages.

     2.   NOTE B SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES; PROPERTY, PLANT AND
          EQUIPMENT: In future annual filings on Form 10-K, the Company will
          disclose the useful lives for each major class of depreciable assets.

     3.   NOTE B SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES; GOODWILL AND
          IDENTIFIABLE INTANGIBLE ASSETS: In future annual filings on Form 10-K,
          the Company will disclose the date of its annual assessment of
          Goodwill for impairment, which is October 1.

     4.   NOTE G INCOME TAXES: The Company has recorded accruals to address
          certain specific federal and state income tax exposures. Such accruals
          include the tax reserves for certain probable tax exposures related to
          tax positions taken in the federal income tax returns for the years
          ended December 31, 1999 and 2000. During the first quarter of 2004,
          the Company reversed $9.6 million of previously established federal
          income tax reserves related to the 1999 tax year, due to the
          expiration of a statute of limitations which had been extended to
          March 31, 2004, without the Internal Revenue Service (IRS) asserting
          any claim.

<PAGE>

          By March 31, 2004, the IRS would have had to issue a notice of
          deficiency. This event did not occur by March 31, 2004 and,
          accordingly, the tax reserves specifically allocated to the 1999 tax
          year were reversed. This reserve reversal was disclosed in our Form
          10-Q for the period ended March 31, 2004, with disclosure included in
          Management's Discussion and Analysis and the Notes to Consolidated
          Financial Statements.

          During the third quarter of 2004, the Company reversed an additional
          $12.5 million of tax reserves into income. As discussed above, these
          income tax reserves were originally provided to address certain
          probable tax exposures in the Company's 2000 federal income tax
          return. The statute of limitations for IRS review with regard to the
          Company's 2000 federal income tax return expired on September 15, 2004
          without the IRS asserting any claim. As such, these tax reserves were
          no longer required and were reversed during the quarter ended
          September 30, 2004. This reserve reversal was disclosed in the Form
          10-Q for the quarter ended September 30, 2004, with disclosure
          included in Management's Discussion and Analysis and the Notes to
          Consolidated Financial Statements.

          In the Company's  Form 10-K for the year ended  December 31, 2004, the
          Company provided disclosure regarding the reversal of $22.1 million of
          income tax  reserves.  Disclosure  is  included  in both  Management's
          Discussion  and  Analysis  and the  Notes  to  Consolidated  Financial
          Statements.

The Company  acknowledges  that: The Company is responsible for the adequacy and
accuracy  of the  disclosure  in the  filings,  staff  comments  or  changes  to
disclosures 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 defense in any proceeding initiated by the Commission or any
person under the laws of the United States.

If you have any further questions, Please contact the undersigned at (203)
849-7999.

Very Truly Yours,


/s/ Mark A. Pompa
-----------------
Mark A. Pompa
Senior Vice President
Chief Accounting Officer and Treasurer


cc.
Leicle E. Chesser, Executive Vice President and Chief Financial Officer
Sheldon I. Cammaker, Executive Vice President & General Counsel
Bernard J. McDonald, Ernst & Young LLP
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