United States securities and exchange commission logo

                             December 1, 2022

       Keefer M. Lehner
       Chief Financial Officer
       KLX Energy Services Holdings, Inc.
       3040 Post Oak Boulevard
       15th Floor
       Houston, TX 77056

                                                        Re: KLX Energy Services
Holdings, Inc.
                                                            Form 10-KT for the
Year Ended December 31, 2021
                                                            Filed March 14,
                                                            Form 8-K filed
November 9, 2022
                                                            File No. 001-38609

       Dear Keefer M. Lehner:

              We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comments. In some of our comments, we
may ask you to
       provide us with information so we may better understand your disclosure.

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to these comments, we may have additional comments.

       Form 10-K for the Year Ended December 31, 2021

       Item 7. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Results of Operations, page 55

   1.                                                   Please expand your
discussion to include an analysis of your operating results for each of
                                                        your reportable
segments. When describing the changes in your results of operations on
                                                        both a consolidated and
segment basis, specifically identify and quantify the key drivers
                                                        contributing the
material changes in each period. Refer to Item 303 of Regulation S-K
                                                        and SEC Release No.
 Keefer M. Lehner
KLX Energy Services Holdings, Inc.
December 1, 2022
Page 2
Form 8-K filed November 9, 2022

Exhibit 99.1
Non-GAAP Financial Measures, page 10

2.       We note you present Adjusted EBITDA margin on a consolidated and
segment basis.
         Please present the most directly comparable GAAP margin with equal or
         prominence to comply with Item 10(e)(1)(i)(A) of Regulation S-K. Refer
to Question
         102.10 of the Compliance and Disclosure Interpretations for Non-GAAP

       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.

      You may contact Myra Moosariparambil, Staff Accountant, at (202) 551-3796
or Craig
Arakawa, Branch Chief, at (202) 551-3650 with any questions.

FirstName LastNameKeefer M. Lehner                         Sincerely,
Comapany NameKLX Energy Services Holdings, Inc.
                                                           Division of
Corporation Finance
December 1, 2022 Page 2                                    Office of Energy &
FirstName LastName