January 8, 2020

Gary Muenster
Chief Financial Officer
ESCO TECHNOLOGIES INC
9900A Clayton Road
St. Louis, MO 63124-1186

       Re: ESCO TECHNOLOGIES INC
           Form 10-K for the fiscal year ended September 30, 2019
           Filed November 29, 2019
           File No. 1-10596

Dear Mr. Muenster:

       We have reviewed your filing 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.

Form 10-K for the fiscal year ended September 30, 2019

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Highlights of 2019 Operations, page 19

1.    We note your presentation of Diluted EPS - As Adjusted and have the
following
      comments:
        Please provide a reconciliation of this non-GAAP measure to the most
directly
          comparable GAAP measure, Diluted EPS, in a more prominent manner,
such as a
          tabular presentation, in accordance with Item 10(e)(1)(i) of
Regulation S-K.
        The adjustments to Diluted EPS appear to be net of income tax. Adding
back
          adjustments, net of tax, is not consistent with the guidance provided
in Question
          102.11 of the the updated Compliance and Disclosure Interpretations
on Non-GAAP
          Financial Measures (April 4, 2018).
      Please revise your future non-GAAP presentations, including disclosures
filed in quarterly
      earnings releases on Form 8-K, accordingly.
 Gary Muenster
ESCO TECHNOLOGIES INC
January 8, 2020
Page 2
Critical Accounting Policies
Revenue Recognition, page 26

2.    We note your disclosure which refers the reader to the Notes to the
Consolidated Financial
      Statements for information regarding the recognition of revenue. Please
revise future
      critical accounting estimates disclosures to provide insight into the
judgments that are
      made in your revenue recognition process. The accounting estimate
disclosures are
      designed to supplement the description of accounting policies in the
notes to the financial
      statements and provide greater insight into the quality and variability
of information
      regarding financial condition and operating performance. Typical
disclosures discuss the
      types of assumptions underlying the most significant and subjective
estimates, provide a
      sensitivity analysis of those assumptions to deviations of actual
results, and disclose the
      circumstances that have resulted in revised assumptions in the past. As
an example, we
      note that significant judgment is used in determining total contract cost
for revenue that is
      recorded over time using the cost-to-cost method.

Goodwill and Other Long-Lived Assets, page 27

3.    We note goodwill represents a substantial element of your Balance Sheet
and your
      accounting policy states the results of your impairment testing indicate
the fair value of
      your NRG subsidiary is not less than the carrying amount. Please modify
your disclosure
      to state, if true, that the results of your impairment testing indicate
the fair values
      substantially exceed the reporting units carrying values for any
reporting units that have
      been quantitatively assessed for impairment. Otherwise, please disclose
the percentage by
      which each reporting units  fair value exceeds its carrying value. If you
performed
      qualitative assessments, please clarify that fact.

        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.

        You may contact Mindy Hooker, Accountant, at (202) 551-3732 or John
Cash, Branch
Chief, at (202) 551-3768 with any questions.



                                                            Sincerely,
FirstName LastNameGary Muenster
                                                            Division of
Corporation Finance
Comapany NameESCO TECHNOLOGIES INC
                                                            Office of
Manufacturing
January 8, 2020 Page 2
cc:       Michelle Marren, Controller
FirstName LastName