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                     August 2, 2022

       Marc Rossiter
       Chief Executive Officer
       Enerflex Ltd.
       1331 Macleod Trail S.E., Suite 904
       Calgary, Alberta, Canada, T2G 0K3

                                                        Re: Enerflex Ltd.
                                                            Amendment No. 2 to
Registration Statement on Form F-4
                                                            Filed July 18, 2022
                                                            File No. 333-263714

       Dear Mr. Rossiter:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our June
6, 2022 letter.
 Marc Rossiter
FirstName  LastNameMarc Rossiter
Enerflex Ltd.
Comapany
August     NameEnerflex Ltd.
       2, 2022
August
Page 2 2, 2022 Page 2
FirstName LastName
Amendment No. 2 to Registration Statement on Form F-4

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Enerflex
First Quarter 2022 Overview, page 247

1.       In your response to prior comment 3, you state that the impact of
inflation to the current
         period and comparative period is not material and therefore no
disclosures have been
         made in the variance analysis of the results. However, we note your
disclosure that the
         gross margin percent was 16.6 percent for the three months ended March
31, 2022 as
         compared to 22.4 percent for the three months ended March 31, 2021 and
that the lower
         gross margin percent was due to a shift in the product mix, less
government grants
         received, and competitive pricing pressures on materials and labor.
Considering that it
         appears that the change in gross margin percent has had a material
impact on your net
         income, please provide further quantification of the specific factors
that impacted your
         gross margin percent during each period presented.
Audited Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 23, Revenue, page F-40

2.       In your response to prior comment 5 you indicate that your finance
lease projects are
         located in a single operating segment. However, it appears that you
have finance leases in
         both your Engineered Systems and Energy Infrastructure product line.
Tell us how you
         considered disclosing the aggregate amount of selling profit on all of
your finance leases
         on a combined basis. Considering your response indicates that finance
lease(s) in
         bookings, backlog, and unsatisfied performance obligations are
material projects, it
         is unclear how your disclosures comply with the objectives of
paragraph 90 of IFRS 16
         and why this is not material information to investors. Identify the
citations in IFRS that
         supports why you believe you are exempt from this disclosure
requirement. Confirm that
         your consolidated financial statements are in compliance with
International Financial
         Reporting Standards as issued by the International Accounting
Standards without this
         disclosure.
Unaudited Interim Consolidated Financial Statements
Interim Consolidated Statements of Cash Flows for the three months ended March
31, 2022,
page F-62

3.       Please clarify why you refer to your change in working capital,
reflected in operating
         activities, as non-cash. In this regard, it appears that these changes
have impacted, or will
         impact, cash. Please revise or advise.
 Marc Rossiter
FirstName  LastNameMarc Rossiter
Enerflex Ltd.
Comapany
August     NameEnerflex Ltd.
       2, 2022
August
Page 3 2, 2022 Page 3
FirstName LastName
4.       We note your restated statement of cash flows. Please revise your
disclosures to describe
         the components of the caption    Net change in working capital
associated with investing
         activities,    and tell us why it is appropriate to reflect these
changes as financing activities.

       You may contact Laura Veator, Senior Staff Accountant, at 202-551-3716
or Stephen
Krikorian, Accounting Branch Chief, at 202-551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact Kyle
Wiley, Staff
Attorney, at 202-344-5791 or Josh Shainess, Legal Branch Chief, at 202-551-7951
with any
other questions.



                                                                 Sincerely,

                                                                 Division of
Corporation Finance
                                                                 Office of
Technology
cc:      Lee McIntyre