<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
United States securities and exchange commission logo





                             November 15, 2021

       Louis Salamone
       Chief Financial Officer
       Babcock & Wilcox Enterprises, Inc.
       1200 East Market Street , Suite 650
       Akron , Ohio 44305

                                                        Re: Babcock & Wilcox
Enterprises, Inc.
                                                            Form 10-K for the
Year Ended Ended December 31, 2020
                                                            Filed March 8, 2021
                                                            File No. 001-36876

       Dear Mr. Salamone:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 Year Ended December 31, 2020

       Non-GAAP Financial Measures, page 34

   1.                                                   We note the first
sentence in the introductory paragraph for Results of Operations where
                                                        you disclose that the
Adjusted EBITDA table is consistent with the way your chief
                                                        operating decision
maker reviews the results of your operations and makes strategic
                                                        decisions about your
business. Following that table, you also present adjusted gross profit
                                                        as a non-GAAP measure
impacting your segment results. Please clarify to us,
                                                        which profitability
measure management believes is the one determined in accordance
                                                        with the measurement
principles most consistent with those used in measuring the
                                                        corresponding amounts
in your financial statements and revise your presentations and
                                                        reconciliations in all
future filings to comply with Question 104.1 of the Division's Non-
                                                        GAAP Financial Measures
Compliance & Disclosure Interpretations, issued April 4, 2018
                                                        and ASC 280-10-50-28 as
necessary.
   2.                                                   We note that you
present Adjusted Gross Profit as a non-GAAP measure and reconcile it
 Louis Salamone
Babcock & Wilcox Enterprises, Inc.
November 15, 2021
Page 2
         to operating loss. As it would appear that gross profit would be the
most comparable
         GAAP measure, please tell us why management decided to reconcile
Adjusted Gross
         Profit to operating loss. In addition, please tell us why the
adjustments made are
         appropriate considering Question 100.01 of the SEC Staff's Compliance
and
         Disclosure Interpretations on non-GAAP Financial Measures.
       In closing, 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 Effie Simpson at (202) 551-3346 or Kevin Woody, Branch
Chief at
(202) 551-3629 with any questions.



FirstName LastNameLouis Salamone                             Sincerely,
Comapany NameBabcock & Wilcox Enterprises, Inc.
                                                             Division of
Corporation Finance
November 15, 2021 Page 2                                     Office of
Manufacturing
FirstName LastName
</TEXT>
</DOCUMENT>
