United States securities and exchange commission logo





                           May 7, 2024

       Aaron Wilkins
       Chief Financial Officer
       NORTHWEST PIPE COMPANY
       201 NE Park Plaza Drive, Suite 100
       Vancouver, WA 98684

                                                        Re: NORTHWEST PIPE
COMPANY
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2023
                                                            Filed March 5, 2024
                                                            File No. 000-27140

       Dear Aaron Wilkins:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment.

              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.
 Aaron Wilkins
FirstName  LastNameAaron Wilkins
NORTHWEST      PIPE COMPANY
Comapany
May  7, 2024NameNORTHWEST PIPE COMPANY
May 7,
Page 2 2024 Page 2
FirstName LastName
Form 10-K for the Fiscal Year Ended December 31, 2023

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Critical Accounting Estimates
Revenue Recognition, page 30

1.       Please revise your disclosures related to Precast revenue to clarify
when you satisfy each
         performance obligation (i.e. when control transfers) as required by
ASC 606-10-50-12(a).
       In closing, 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.

       Please contact Stephany Yang at 202-551-3167 or Melissa Gilmore at
202-551-3777 with
any questions.



                                                              Sincerely,

                                                              Division of
Corporation Finance
                                                              Office of
Manufacturing