Broadwind Energy, Inc.

47 E. Chicago Avenue Suite 332

Naperville, IL 60540

August 13, 2009

VIA FACSIMILE AND EDGAR

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Attention:  Mr. Jay Ingram

Legal Branch Chief

Re:	Broadwind Energy, Inc.
	Amendment No. 2 to Registration Statement on Form S-1 (File No. 333-159487)

Ladies and Gentlemen:

Pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, Broadwind Energy, Inc., a Delaware corporation (the “Company”), hereby requests that Amendment No. 2 to the Registration Statement on Form S-1 (File No. 333-159487) (the “Amendment No. 2”) be declared effective at 12:00 p.m., Eastern Standard Time on August 17, 2009 or as soon thereafter as practicable.

In connection with this request, the Company acknowledges that:

·should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the Amendment No. 2 effective, it does not foreclose the Commission from taking any action with respect to the Amendment No. 2;

·the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the Amendment No. 2 effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

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

We appreciate your attention to this matter.  If you have any questions or require further information, please contact Robert Verigan at (312) 853-4348 or the undersigned at (630) 637-0315.

Very truly yours,
BROADWIND ENERGY, INC.
By:	/s/ J.D. Rubin
	J.D. Rubin
	Vice President and General Counsel

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