United States securities and exchange commission logo





                              October 26, 2021

       William F. Concannon
       Chief Executive Officer
       CBRE Acquisition Holdings, Inc.
       2100 McKinney Avenue, Suite 1250
       Dallas, TX 75201

                                                        Re: CBRE Acquisition
Holdings, Inc.
                                                            Amendment No. 2 to
Registration Statement on Form S-4
                                                            Filed October 15,
2021
                                                            File No. 333-258700

       Dear Mr. Concannon:

             We have reviewed your amended registration statement 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 8, 2021 letter.

       Amendment No. 2 to Registration Statement on Form S-4

       The Business Combination
       Certain Projected Financial Information of Altus, page 128

   1.                                                   We note your revised
disclosure in response to prior comment 4 and reissue it in part.
                                                        Please expand your
disclosure to qualitatively and quantitatively describe your
                                                        assumptions as to
competition, general business, economic, market and financial
                                                        conditions and matters
specific to the business of Altus that underlie your disclosed
                                                        projections, including
the basis for projecting total estimated revenue growth in 2022,
                                                        2023 and 2024 and the
factors or contingencies that could prevent such growth from
                                                        materializing.
 William F. Concannon
CBRE Acquisition Holdings, Inc.
October 26, 2021
Page 2
2.     We note your response to prior comment 5 states that the company
acknowledges its
       obligations under Item 10(b)(3)(iii) of Regulation S-K and indicates
that the company
       will update or revise its unaudited prospective financial information
where management
       knows or has reason to know that its previously disclosed projections no
longer have a
       reasonable basis. To avoid confusion, please revise your disclosure of
the disclaimer on
       page 128. Such disclosure appears inconsistent with your response in
that it disclaims any
       obligation to update, revise or correct the projections to reflect
circumstances existing or
       arising after the date such projections were generated or to reflect the
occurrence of future
       events, even in the event that any or all of the assumptions underlying
the projections are
       shown to be in error.
Certain U.S. Federal Income Tax Considerations, page 149

3.     We note that the tax opinion filed as Exhibit 8.1 states that it is the
opinion of Simpson
       Thacher & Bartlett LLP that the merger will qualify as a
"reorganization" within the
       meaning of Section 368(a) of the Code and that the disclosures in this
section of the
       prospectus constitute the opinion of counsel insofar as it expresses
conclusions as to the
       application of U.S. federal income tax law. Please revise your
disclosure in this section to
       clearly identify and articulate the opinion being rendered by tax
counsel. Refer to Section
       III.B.2 and III.C of Staff Legal Bulletin No. 19.
Exhibits

4.     We note you have filed forms of counsel's legal and tax opinions. Please
file executed
       versions of the legal and tax opinions.
        You may contact Jenifer Gallagher, Staff Accountant, at (202) 551-3706
or Karl Hiller,
Accounting Branch Chief, at (202) 551-3686 if you have questions regarding
comments on the
financial statements and related matters. Please contact Karina Dorin, Staff
Attorney, at (202)
551-3763 or Loan Lauren Nguyen, Legal Branch Chief, at (202) 551-3642 with any
other
questions.



                                                             Sincerely,
FirstName LastNameWilliam F. Concannon
                                                             Division of
Corporation Finance
Comapany NameCBRE Acquisition Holdings, Inc.
                                                             Office of Energy &
Transportation
October 26, 2021 Page 2
cc:       William B. Brentani
FirstName LastName