United States securities and exchange commission logo October 27, 2020 Scott Montross President and Chief Executive Officer NORTHWEST PIPE CO 201 NE Park Plaza Drive, Suite 100 Vancouver, Washington 98684 Re: NORTHWEST PIPE CO Registration Statement on Form S-3 Filed October 23, 2020 File No. 333-249637 Dear Mr. Montross: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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 Geoff Kruczek at (202) 551-3641 with any questions. Sincerely, Division of Corporation Finance Office of Manufacturing cc: Gregory Struxness