March 3, 2025

Brett Urban
Chief Financial Officer
BrightView Holdings, Inc.
980 Jolly Road
Blue Bell, PA 19422

       Re: BrightView Holdings, Inc.
           Form 10-K for Fiscal Year Ended September 30, 2024
           Form 10-Q for Fiscal Quarter Ended December 31, 2024
           File No. 001-38579
Dear Brett Urban:

        We have reviewed your February 18, 2025 response to our comment letter
and have
the following comments.

       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
29, 2025 letter.

Form 10-K for Fiscal Year Ended September 30, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations, page 34

1.     To the extent that the One Brightview Initiative is reasonably likely to
have a material
       effect on financial condition or operating performance, revise to
include additional
       disclosures within future filings about the One Brightview Initiative
and its expected
       impact on operating results and future trends. Refer to Item
303(b)(2)(ii) of
       Regulation S-K and the instructions thereto, and sections III.A and B.3
of Release 33-
       8350.
 March 3, 2025
Page 2
Non-GAAP Financial Measures, page 42

2.     Reference your response to prior comment 2. Please tell us more about
the One
       Brightview Initiative, including describing the overall
transformational    changes and
       how long the initiative will continue. For example, explain in more
detail the nature of
       the transformation costs incurred to centralize business support
functions, create the
       new procurement strategy, and describe what pilot programs were created.
Form 10-Q for Fiscal Quarter Ended December 31, 2024
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Non-GAAP Financial Measures, page 31

3.     We see that adjusted EBITDA and adjusted net income for the first
quarter of FY25
       continue to include a non-GAAP adjustment for "Business transformation
and
       integration costs", which is comprised primarily of IT infrastructure,
transformation,
       and other of $10.3 million. Please describe in detail, the nature and
composition of the
       transformation and integration activities, including a quantitative
breakdown of each
       category of costs for each period presented.

       Please contact Kristin Lochhead at 202-551-3664 or Li Xiao at
202-551-4391 if you
have questions regarding comments on the financial statements and related
matters.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of
Industrial Applications and
                                                            Services