July 24, 2018

Brandon Pedersen
Executive Vice President and Chief Financial Officer
Alaska Air Group, Inc.
19300 International Boulevard
Seattle WA 98188

       Re: Alaska Air Group, Inc.
           Form 10-K For the Fiscal Year Ended December 31, 2017
           Filed February 15, 2018
           File No. 001-08957
           Form 10-Q For the Quarterly Period Ended March 31, 2018
           Filed May 4, 2018
           File No. 001-08957
           Form 8-K filed April 23, 2018
           File No. 001-08957

Dear Mr. Pedersen:

       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 8-K Furnished April 23, 2018

Exhibit 99.1, page 5

1.    You disclose the measure "debt-to-capitalization" ratio. Please consider
disclosing and
      quantifying the components of the computation so that investors may more
      readily understand the measure.
 Brandon Pedersen
Alaska Air Group, Inc.
July 24, 2018
Page 2
Form 10-Q For the Quarterly Period Ended March 31, 2018

Note 3. Revenue
Passenger Ticket and Ancillary Services Revenue, page 12

2.       You disclose that passenger ticket breakage is recorded in advance of
the flight date using
         estimates based on the company's historical experience of expired
tickets, and other facts
         such as program changes and modifications. Please explain to us why
the recognition of
         breakage in advance of the flight date rather than on the scheduled
flight date is
         appropriate and represents the expected breakage amount in proportion
to the pattern of
         rights exercised by the customer as prescribed in ASC 606-10-55-48.
Additionally,
         explain to us your ticket validity policy (i.e., the status and value
of a ticket after its
         scheduled departure date but prior to its contractual expiration date
and exceptions made
         to accept invalid/expired tickets) and how it is factored into
determining the amount of
         breakage.
       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 Patrick Kuhn at (202) 551-3308 or Doug Jones at (202)
551-3309 with
any questions.

FirstName LastNameBrandon Pedersen
Comapany NameAlaska Air Group, Inc.
                                                              Division of
Corporation Finance
July 24, 2018 Page 2                                          Office of
Transportation and Leisure
FirstName LastName