United States securities and exchange commission logo March 13, 2024 Steven Burdick Executive Vice President and Chief Financial Officer Tetra Tech, Inc. 3475 East Foothill Boulevard Pasadena, CA 91107 Re: Tetra Tech, Inc. Form 10-K for Fiscal Year Ended October 1, 2023 Form 8-K Furnished November 15, 2023 Response dated March 1, 2024 File No. 000-19655 Dear Steven Burdick: We have reviewed your March 1, 2024 response to our comment letter and have the following comment(s). Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our January 30, 2024 letter. Investor Presentation for Earnings Call Held on November 16, 2023 EBITDA Margin Trend on U.S. and International Reporting Basis Reconciliation Summary for EBITDA - IFRS and Net Service Revenue (NSR) 1. We note your response to prior comment 3. Please tell us: Whether you applied IFRS to all other accounting transactions that would factor into the determination of Adjusted IFRS EBITDA, Why you believe GAAP net income is more directly comparable to an adjusted IFRS measure of profit than IFRS net income, and How the presentation of Adjusted IFRS EBITDA complies with the guidance contained in Question 100.04 of the Staff's Compliance and Disclosure Interpretations on Non-GAAP Financial Measures. Steven Burdick Tetra Tech, Inc. March 13, 2024 Page 2 2. Please explain why you believe it is appropriate to exclude revenue generated from RPS from the calculation of Net Service Revenue (NSR) for purposes of determining Adjusted IFRS EBITDA as a percentage of adjusted NSR. Please contact Robert Shapiro at 202-551-3273 or Lyn Shenk at 202-551-3380 if you have questions regarding comments on the financial statements and related matters. FirstName LastNameSteven Burdick Sincerely, Comapany NameTetra Tech, Inc. Division of Corporation Finance March 13, 2024 Page 2 Office of Trade & Services FirstName LastName