EXHIBIT 99.1

May 16, 2002



United States Securities and Exchange Commission
Washington, DC  20549

Re:  Temporary Note 3T to Article 3 of Regulation S-X

Ladies and Gentlemen:

The Plan Administrator has obtained representation from Arthur Andersen LLP,
dated as of May 16, 2002, that states:

"We have audited the statement of net assets available for plan benefits of the
Comfort Systems USA, Inc. 401(k) Plan as of December 31, 2001, and the related
statement of changes in net assets available for plan benefits for the year then
ended and have issued our report thereon dated May 16, 2002. We represent that
this audit was subject to our quality control system for the U.S. accounting and
auditing practice to provide reasonable assurance that the engagement was
conducted in compliance with professional standards and that there was
appropriate continuity of Arthur Andersen LLP personnel working on the audit and
availability of national office consultation. Availability of personnel at
foreign affiliates of Arthur Andersen LLP is not relevant to this audit."

COMFORT SYSTEMS USA, INC. 401(k) PLAN

By: /s/ J. GORDON BEITTENMILLER
   -------------------------------------
      J. Gordon Beittenmiller
      Executive Vice President and
      Chief Financial Officer of
      Comfort Systems USA, Inc.
      401(k) Investment Committee Member