March 10, 2020 W. Troy Rudd Executive Vice President and Chief Financial Officer AECOM 1999 Avenue of the Stars, Suite 2600 Los Angeles, CA 90067 Re: AECOM Form 10-K for the Fiscal Year Ended September 30, 2019 Filed November 13, 2019 File No. 000-52423 Dear Mr. Rudd: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Trade & Services cc: Charles Szorgot