SCHEDULE 14A
                      SCHEDULE 14 INFORMATION


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Comfort Systems USA, Inc.


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Sheet Metal Workers' International Association

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                        Date of Release by SMWIA: 1/09/02


                  Comfort Systems Shareholder Newsletter

                                   Issue One

                   Large Majority Supports Effort To
                   Restrict Replacement Stock Options


Some 676 Comfort Systems shareholders responded to a mailing
asking for their views on limiting future stock option grants.
Over 580, or approximately 86%, support efforts to adopt a policy
of not repricing options or granting new ones because the old
ones go underwater, unless the shareholders specifically approve
such action. The policy was proposed in response to a company
disclosure that options were granted to five executives because
previously awarded options were underwater.

Of the respondents whose number of shares could be determined,
holders of 1.36 million shares supported the proposal and holders
of 435,000 shares opposed.  Many large shareholders voiced
support for the view that repricing of options because the
exercise price is below market value (or the granting of new
options) is unfair to shareholders.

Some respondents apparently misunderstood the proposal because
they stated that they opposed it because they opposed further
stock dilution or opposed current management.  The proposal does
not further stock dilution nor take a position on current
management.

               SEC Asked To Investigate Comfort Systems
               Accounting For Replacement Stock Options

The SMWIA is concerned that Comfort Systems may be inaccurately
reporting earnings because it has not taken a charge for the
value of the replacement stock options.  We have asked the
Securities and Exchange Commission to investigate the company's
accounting practices in this matter.

The Financial Accounting Standards Board, in a statement known as
Interpretation No. 44, requires companies to take a quarterly
charge for the increased value of any replacement stock options.

Comfort Systems management has asserted that it believes the
stock options do not necessitate a charge to earnings.  Because
the issue is new, we have asked the SEC to investigate and advise
whether a charge to earnings is required.


The Sheet Metal Workers' International Association, which owns
1,400 shares of company stock and is the proposal sponsor,
represents over 150,000 members in the sheet metal industry,
including approximately 500 Comfort Systems employees.