December 4, 2018

Robert J. Simmons
Chief Financial Officer
SkyWest, Inc.
444 South River Road
St. George, Utah 84790

       Re: SkyWest, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed on February 26, 2018
           File No. 000-14719

Dear Mr. Simmons:

       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 10-K for the Year Ended December 31, 2017

Item 8. Financial Statements
Note 1. Nature of Operations and Summary of Significant Accounting Policies
Passenger and Ground Handling Revenues , page 62

1.    You disclose under your fixed fee agreements a portion of the
compensation is to
      reimburse you for aircraft ownership costs. It appears under the
ExpressJet United Express
      ERJ Agreement and certain aircraft operating under fixed-fee contracts
with Delta your
      aircraft ownership costs are nominal as the airline partner provides the
aircraft to you for a
      nominal amount. Please tell us the basis for the total amount of
compensation received by
      you under these arrangements in which you are provided aircraft at
nominal cost and how
      you determine the amount of the compensation deemed to be rental income
to you. Also
      clarify for us the form of the total compensation received by you under
these
      arrangements, for example, all in cash or some other basis, or a
combination of cash and
      some other basis. If the compensation is on some other basis, please tell
us the basis and
 Robert J. Simmons
SkyWest, Inc.
December 4, 2018
Page 2
         how the value is determined.
Note 5. Commitments and Contingencies, page 73

2.       You disclose the trusts through which you lease your aircraft are
variable interest entities.
         However, since these are single owner trusts in which the Company does
not participate
         you are not considered the primary beneficiary. Please clarify what
you mean by "the
         Company does not participate." Additionally, tell us who is the owner
of the trusts and
         describe for us the material features of these trusts, your
association/interaction with them
         in leasing your aircraft from them and the basis for your conclusion
that you are not the
         primary beneficiary. Further, tell us if you guarantee any portion of
the residual values of
         the leased assets or have a fixed price purchase option to acquire the
leased assets at the
         end of the lease terms.
       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 Aamira Chaudhry at 202-551-3389 or Doug Jones at
202-551-3309
with any questions.



FirstName LastNameRobert J. Simmons                             Sincerely,
Comapany NameSkyWest, Inc.
                                                                Division of
Corporation Finance
December 4, 2018 Page 2                                         Office of
Transportation and Leisure
FirstName LastName