United States securities and exchange commission logo

                             July 22, 2021

       Dave Davis
       President and Chief Financial Officer
       Sun Country Airlines Holdings, Inc.
       2005 Cargo Road
       Minneapolis, MN 55450

                                                        Re: Sun Country
Airlines Holdings, Inc.
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted July 16,
                                                            CIK No. 0001743907

       Dear Mr. Davis:

                                                        This is to advise you
that we do not intend to review your registration statement.

               We request that you publicly file your registration statement no
later than 48 hours prior
       to the requested effective date and time. Please refer to Rules 460 and
461 regarding requests for
       acceleration. 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.

              Please contact Anuja A. Majmudar, Attorney-Advisor, at
202-551-3844 with any


                             Division of Corporation Finance

                             Office of Energy & Transportation
       cc:                                              Brian M. Janson