UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-5546

         DIVISION OF
CORPORATION FINANCE


Mail Stop 5546
								September 14, 2005

Stewart & Stevenson Services, Inc.
2707 North Loop West
Houston, TX  77008

      Re:	Stewart & Stevenson Services, Inc.
      Form 10-K for the Fiscal Year Ended January 31, 2005
      Forms 10-Q for Fiscal Quarters Ended
      July 31, 2004, April 30, 2005 and July 30, 2005
 		File No. 001-11443

Dear Mr. Lukens:

      We have limited our review of the above filings to
disclosures
relating to your contacts with countries that have been identified
as
state sponsors of terrorism, and we will make no further review of
these filings.  Our review with respect to this issue does not
preclude further review by the Assistant Director group with
respect
to other issues.  At this juncture, we are asking you to provide
us
with supplemental information so that we may better understand
your
disclosure.  Please be as detailed as necessary in the explanation
you provide for this comment.  After reviewing this information,
we
may or may not raise additional comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your
filings.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

General

1. We note the statement on page 19 of your Form 10-Q for the
fiscal
quarter ended July 30, 2005 that "[f]iscal 2004 results included a
$0.4 million inventory impairment charge resulting from U.S. trade
sanctions against Syria and the $0.6 million gain associated with
the
disposal of an idle manufacturing facility."  We note similar
statements in your Forms 10-Q for the periods ended April 30, 2005
and July 31, 2004.

In light of the fact that the U.S. State Department has identified
Syria as a state sponsor of terrorism and Syria is subject to
economic sanctions administered by the Treasury Department`s
Office
of Foreign Assets Control, please describe for us your prior,
current
and anticipated operations in, and other direct or indirect
contacts
with, Syria.  Provide us with further information regarding the
above-referenced inventory impairment charge, including the nature
and extent of your contacts with Syria that resulted in your
taking
the charge.  Please also describe the materiality of your
operations
in, and contacts with, Syria, and your view as to whether they
constitute a material investment risk for your security holders.

In preparing your response please consider that evaluations of
materiality should not be based solely on quantitative factors,
but
should include consideration of all factors that a reasonable
investor would deem important in making an investment decision,
including the potential impact of corporate activities upon a
company`s reputation and share value.  In this regard, we note
that
legislation requiring divestment from, or reporting of interests
in,
companies that do business with U.S.-designated state sponsors of
terrorism has been adopted by Arizona and Louisiana.

      Please respond to this comment within 10 business days or
tell
us when you will provide us with a response.  Please understand
that
we may have additional comments after reviewing your amendment and
responses to our comments.  Please file your response letter on
EDGAR.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filings include all information required under the Exchange Act of
1934 and that they have provided all information investors require
for an informed investment decision.  Since the company and its
management are in possession of all facts relating to the
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      In connection with responding to our comment, please
provide,
in writing, a statement from the company acknowledging that:

the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

staff comments or changes to disclosure in response to staff
comments
do not foreclose the Commission from taking any action with
respect
to the filings; and

the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filings or
in
response to our comments on your filings.

      Please contact James Lopez at (202) 551-3536 if you have any
questions about the comment or our review.  You may also contact
me
at (202) 551-3470.



								Sincerely,




								Cecilia D. Blye, Chief
								Office of Global Security
Risk




cc: 	Peggy Fisher
		Assistant Director
		Division of Corporation Finance
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Max L. Lukens
Stewart & Stevenson Services, Inc.
September 14, 2005
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