August 15, 2019

Quint O. Turner
Chief Financial Officer
Air Transport Services Group, Inc.
145 Hunter Drive
Wilmington, OH 45177

       Re: Air Transport Services Group, Inc.
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed March 1, 2019
           Form 8-K Furnished August 5, 2019
           File No. 000-50368

Dear Mr. Turner:

       We have reviewed your filings 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 August 5, 2019

Exhibit 99.1
Outlook, page 3

1.    You provide a projection of the non-GAAP measure "adjusted EBITDA."
Please present
      the comparable GAAP measure and reconciliation thereto pursuant to Item
10(e)(1)(i)(A)
      and (B) of Regulation S-K as directed by instruction 2 to Item 2.02 of
Form 8-K. Also
      refer to question 102.10 in staff's Compliance and Disclosure
Interpretations "Non-GAAP
      Financial Measures" for further guidance.
Form 10-K for Fiscal Year Ended December 31, 2018

Note O - Segment and Revenue Information, page 81

2.    We note your revenues for customer contracts for airframe maintenance and
aircraft
 Quint O. Turner
Air Transport Services Group, Inc.
August 15, 2019
Page 2
         modification services are generally recognized over time based on the
percentage of costs
         completed. Please tell us your consideration of disclosing remaining
performance
         obligations associated with these revenues pursuant to FASB ASC
606-10-50-13 and an
         explanation of why the method used provides a faithful depiction of
the transfer of the
         services pursuant to 50-18.b.
        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 Amy Geddes at 202-551-3304 or Doug Jones at 202-551-3309
if you
have questions regarding comments on the financial statements and related
matters, or any other
questions.



FirstName LastNameQuint O. Turner                            Sincerely,
Comapany NameAir Transport Services Group, Inc.
                                                             Division of
Corporation Finance
August 15, 2019 Page 2                                       Office of
Transportation and Leisure
FirstName LastName