Cover Letter

ESCO TECHNOLOGIES INC
9900A Clayton Rd.
St. Louis, Mo. 63124-1186


March 1, 2006

Mr. Joseph Foti
Senior Assistant Chief Accountant
Division of Corporation Finance
Securities and Exchange Commission
100F Street, N.E.
Washington, D.C. 20549

RE:  ESCO Technologies Inc.
         File No. 1-10596
         Form 10-K for the Fiscal Year Ended September 30, 2005

Dear Mr. Foti:

The attachment to this letter sets forth the response of ESCO  Technologies Inc.
(the  "Company")  to the comment of the Division of  Corporation  Finance of the
Securities and Exchange  Commission (the  "Commission")  dated February 2, 2006,
with respect to the above referenced  filing. We have duplicated the comment set
forth in the comment letter in the attachment and have provided our response.

If you have any questions or if you require  additional  information,  please do
not hesitate to contact me at 314-213-7246.

Sincerely,




/s/ Gary E. Muenster
Gary E. Muenster
Senior Vice President
and Chief Financial Officer
ESCO Technologies Inc.
9900A Clayton Road
St. Louis, MO  63124