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                             May 18, 2022

       Allan Dicks
       Chief Financial Officer
       Montrose Environmental Group, Inc.
       5120 Northshore Drive
       North Little Rock, Arkansas 72118

                                                        Re: Montrose
Environmental Group, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed March 1, 2022
                                                            File No. 001-39394

       Dear Mr. Dicks:

              We have reviewed your May 11, 2022 response to our comment letter
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. Unless we note otherwise, our references to prior comments are
to comments in our
       April 28, 2022 letter.

       Form 10-K for Fiscal Year Ended December 31, 2021

       Item 7. Management's Discussion and Analysis
       Segment Results of Operations
       Year Ended December 31, 2021 Compared to the Year Ended December 31,
2020
       Revenues, page 61

   1.                                                   We note your response
to prior comment 2. It appears that quantifying the impact of
                                                        COVID-19 related
revenue would be useful for investors to analyze period-over-period
                                                        changes, in addition to
the information provided in your response regarding your
                                                        availability and
prioritization of resources during the period in which COVID-19 specific
                                                        work was performed.
Please provide this information pursuant to Item 303(a) of
                                                        Regulation S-K which
states "The discussion and analysis must focus specifically on
                                                        material events and
uncertainties known to management that are reasonably likely to
 Allan Dicks
Montrose Environmental Group, Inc.
May 18, 2022
Page 2
         cause reported financial information not to be necessarily indicative
of future operating
         results or of future financial condition. This includes descriptions
and amounts of matters
         that have had a material impact on reported operations, as well as
matters that are
         reasonably likely based on management's assessment to have a material
impact on future
         operations."

         Additionally, when addressing the quantification of the impact of a
full year of CTEH
         revenues in your Form 10-K for the fiscal year ended 2021, we note
that you make
         reference to your Quarterly Reports on Form 10-Q. Pursuant to
Instruction 1 to Item
         303(b) of Regulation S-K, your discussion should cover the periods
covered by the
         financial statements. Please advise, or revise accordingly.
Non-GAAP Financial Information, page 72

2.       We note per your response to prior comment 3 that start-up losses and
investment in new
         services "relate to entirely new capabilities and geographies" and
your acquisitions are
         each a "distinct event rather than being part of an ongoing,
inter-related sequence of
         transactions with related costs." While these costs may differ from
your day-to-
         day activities, it appears that these costs are core to the operations
of the company. We
         also note from your disclosure that you have historically incurred
these types of costs and
         anticipate continuing to incur these costs as part of your growth
strategy. Specifically, on
         page 23 of your Form 10-K, you disclose "[o]ur continued success and
growth depend
         upon our ability to anticipate these challenges and to innovate by
enhancing our existing
         services and developing and successfully implementing new services,"
and "[a] significant
         portion of our historical growth has occurred through acquisitions,
and we anticipate
         continued growth through acquisitions in the future." We continue to
believe that based on
         the historical and continuing strategy of implementing new services
and acquisitions,
         these excluded costs represent normal, recurring, cash operating
expenses necessary to
         operate your business. Please advise, or revise accordingly. Refer to
Question 100.01
         of the staff's Compliance and Disclosure Interpretation on Non-GAAP
Financial
         Measures.
      You may contact Abe Friedman at 202-551-8298 or Theresa Brillant at
202-551-
3307 with any questions.



FirstName LastNameAllan Dicks                                  Sincerely,
Comapany NameMontrose Environmental Group, Inc.
                                                               Division of
Corporation Finance
May 18, 2022 Page 2                                            Office of Trade
& Services
FirstName LastName