United States securities and exchange commission logo January 4, 2023 Jude Bricker Chief Executive Officer Sun Country Airlines Holdings, Inc. 2005 Cargo Road Minneapolis, MN 55450 Re: Sun Country Airlines Holdings, Inc. Registration Statement on Form S-3 Filed December 27, 2022 File No. 333-269023 Dear Jude Bricker: This is to advise you that we have not reviewed and will not review your registration statement. 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 Cheryl Brown, Staff Attorney, at (202) 551-3905 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Brian M. Janson