PROXY STATEMENT

The enclosed form is not a proxy voting card, but only a
voluntary survey.

Released to Shareholders 11/21/01

Sheet Metal Workers International Association
1750 New York Avenue NW
Washington, D.C. 20006
Tel. (800) 457-7694
Fax: (202) 662-0891

NOTICE OF INTENDED PROXY CONTEST AT COMFORT SYSTEMS USA

To Fellow Comfort Systems USA shareholders:

     I.   WITHOUT SHAREHOLDER APPROVAL, SHOULD THIS COMPANY GRANT
          ITS EXECUTIVES NEW STOCK OPTIONS JUST BECAUSE THE
          STOCK'S MARKET PRICE DROPPED BELOW THE EXERCISE PRICE
          OF PRIOR OPTIONS?

Our International owns stock in the Company and also has
interests in the Company going beyond stock ownership, as the
representative of several hundred Company employees.

Stock options are supposed to link executive compensation to a
company's stock performance: if the company's stock goes up, then
the options can be exercised at a price below the new market
price, benefitting company executives because they presumably
helped get the stock price up.  If the stock drops, options end
up "underwater" (their exercise price is above market price, so
the executive would not profit from exercising them).

However, stock options get delinked from stock performance if the
Board of Directors reprices options downwards after executives
fail to improve a company's stock price.   Another way for a
board to accomplish basically the same thing as repricing is to
react to old options ending up underwater by issuing new options
at a lower price.

Last year's proxy statement reveals that the Company did exactly
this: "In late 2000, an aggregate of 300,000 options were granted
to five individuals excluding Mr. Murdy with existing options
because the previous options granted to these individuals were at
exercise prices significantly higher than year end 2000 market
value."

We intend to present a proposal at the next shareholders meeting
asking the Board to adopt a policy of not repricing options or
granting new ones because old ones go underwater, unless
shareholders approve such action.  The full text of our proposal
is in Section VI below.

We believe that repricing of options (or granting new options
just because old options end up underwater is unfair to
shareholders.  A deal is a deal, or should be.  In our view
repricing or replacing underwater options not only reduces
executives' incentive to work hard for shareholders, but also in
our view tends to mislead shareholders about the true value of an
executive's compensation.

Top executives often justify high-level compensation by claiming
that much of it depends on stock price. That justification in our
opinion carries little weight if after the stock dives, the
executive's options just get repriced or replaced by new cheaper
options.  In our experience, employee morale depends largely on
seeing that everyone -  executive or not - is in the same boat.

Similar proposals have been made of other companies by the New
York City and State pension funds and other institutional
investors.  The proposal at Sprint received 46 percent of the
votes cast at the 2001 annual meeting. Some companies have
voluntarily adopted a policy similar to the one we propose, such
as Earthgrains and Lone Star Steakhouse.

While many shareholders oppose repricing on principle, some
investors prefer to support shareholder proposals only when
management is underperforming.  If you're one of those,
please consider the Company's stock closing price on the day of
the last four annual meetings:

        $21.125 in 1998.
        $16.3125 in 1999.
        $6.75 in 2000
        $4.24 in 2001.

This three-year period witnessed an 80% decline in shareholder
value.

II.   PROXY VOTING:

The enclosed form is not a proxy voting card, but only a
voluntary survey.  We intend to solicit votes for the proposal in
a few months using our own proxy card and proxy statement.  These
probably cannot be sent you until after you receive a proxy
statement and card from the Company.  The Company's proxy card
may not include our proposal.

IF YOU SUPPORT OUR PROPOSAL, DO NOT SEND BACK A PROXY CARD TO
MANAGEMENT UNLESS IT INCLUDES OUR PROPOSAL.  WAIT UNTIL YOU
RECEIVE OUR PROXY CARD.

We intend to solicit at least a majority of the voting power of
the outstanding stock.  The Company's annual shareholders meeting
generally occurs the third week of May, generally at a hotel near
the company's headquarters, 777 Post Oak Blvd., Houston, TX
77056.  Our proposal is a nonbinding recommendation to the Board.

III.      PROXY SOLICITATION:

This solicitation is conducted by Sheet Metal Workers'
International Association (SMWIA),which owns 1,400 shares of
Comfort Systems USA stock and represents about 500 Comfort
Systems employees for collective bargaining purposes.  Several
hundred are represented by other unions: a total of approximately
2,795 are unionized, out of approximately 10,000 nonmanagement
personnel.  To SMWIA's knowledge, there are no strikes, contract
disputes, picketing, or boycotts going on currently.  We do not
seek your support in labor matters. SMWIA will vote each proxy
card it receives in accordance with the shareholder's
instructions.  SMWIA will not seek any discretionary voting
authority for the shareholders meeting:  rather, it will vote
stock solely as directed by the shareholder.  SMWIA will bear all
solicitation costs (anticipated at $5000) and will not seek
reimbursement from the Company.

IV.       MORE INFORMATION ON EXECUTIVE STOCK OPTIONS AND OTHER
          COMPENSATION:

We incorporate by reference the information on executive
compensation contained at pp. 8-12 of the Company's prior proxy
statement.  This is available at www.sec.gov or upon request from
SMWIA.

V.        SHAREHOLDER PROPOSALS:

If a shareholder has owned more than $2000 worth of stock for
more than a year and meets the other criteria of SEC Rule 14a8,
then he or she has the legal right to have a proposal appear in
management's upcoming proxy statement and proxy card. The
deadline for shareholders to submit proposals for inclusion in
management's proxy materials is December 1, 2001.

VI.       TEXT OF OUR PROPOSAL:

RESOLVED that shareholders urge the Board of Directors to adopt a
policy that the Company shall not, without prior approval of the
holders of a majority of stock, reprice stock options already
granted to any executive officer or director to a lower exercise
price, nor terminate and regrant any such option at a lower
price, nor grant new options to such persons on account of the
market price dropping below the exercise price of prior options.
This proposal shall not be construed as asking the Board to
breach any existing contract nor to amend any option plan
without shareholder approval.


PLEASE RETURN THE ENCLOSED SURVEY TODAY.

For more information, contact Allen Smith at SMWIA at (800)
457-7694.



                SURVEY OF SHAREHOLDERS OF COMFORT SYSTEMS USA

This is a voluntary survey, not a proxy card, and cannot be used
to vote on the shareholder proposal. Your identity will be kept
confidential unless you specifically authorize to the
contrary.  The information from your response will be used solely
for communicating about shareholder voting issues.


YOUR VIEW OF OUR SHAREHOLDER PROPOSAL FOR SHAREHOLDER CONTROL
OVER STOCK OPTION REPRICING:

____      Strongly support
____      Likely to support
____      Likely to oppose because ______________________

____      Undecided


____      Please send me more information about the issues on
          which shareholders will be voting.



___________________________________________    _________________
PRINT SHAREHOLDER NAME                         # SHARES(optional)

Mailing address:  _________________________________________

Email address:    _________________________________________

Telephone:        _________________________________________

Fax:              _________________________________________


Please return to SMWIA by December 31, 2001 in the enclosed
envelope, or fax to (202) 662-0891.