United States securities and exchange commission logo August 24, 2021 W. Troy Rudd Chief Executive Officer AECOM 300 South Grand Avenue, 9th Floor Los Angeles, California 90071 Re: AECOM Form 10-K for the Fiscal Year Ended September 30, 2020 Filed November 19, 2020 Form 10-Q for the Fiscal Period Ended March 31, 2021 Filed May 12, 2021 File No. 000-52423 Dear Mr. Rudd: We have completed our review of your filings. 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