SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549 -0306

       DIVISION OF
CORPORATION FINANCE

 Mailstop 3233  June 26, 2017

Via E -mail
J. Brendan Herron
Chief Financial Officer and Executive Vice President
Hannon Armstrong Sustainable Infrastructure Capital, Inc.
1906 Towne Centre Blvd, Suite 370
Annapolis, MD 21401

 Re:      Hannon Armstrong Sustainable Infrastructure Capital, Inc.
   Form 10 -K for Fiscal Year Ended
   December 31, 20 16
   Filed  February 24, 2017
   File No.  001-35877

Dear Mr. Herron :

We have reviewed your filing s 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 this letter within ten business days by providing the requested
information or by advising us when you will provide the requested response.   If you do
not believe our comments apply to your facts and circumstance s, please tell us why in
your response.

After reviewing the information you provide in response to these comments, we
may have additional comments.

Form 10 -K for the fiscal year ending December 31, 2016

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Non-GAAP Financial Measures

Core Earnings, page 72

1. We note that your measure of core earnings generally recognizes income earned
from equity method investments as your initial capital investment amortized over
the life of the project using a con stant yield.  We further note this methodology

J. Brendan Herron
Hannon Armstrong Sustainable Infrastructure Capital, Inc.
June 26, 2017
Page 2

 differs from the hypothetical liquidation at book value method used to calculate
your share of earnings in your financial statements.  Please tell us how you
applied the guidance in question 100.04 in the C&DI  related to Non -GAAP
Financial Measures in determining your adjustments were appropriate.

Item 8. Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements

2. Summary of Significant Accounting Policies

Financing Receivables, page 92

2. We note your disclosure that financing receivables consists of energy efficiency
and renewable energy project loans, receivables and direct financing leases.
Please provide us with a disaggregated schedule of your financing receivabl es by
asset class (loans, direct financing leases etc.).  In addition, please tell us how you
determined it would be appropriate to aggregate these asset classes within your
financial statements.  We may have additional comments once we have reviewed
your response.

Note 6 – Our Portfolio, page 104

3. We note you have $22 million of financing receivables that are considered non -
investment grade.  Please tell us how you determined none of these receivables
were considered impaired or should be on nonaccrual st atus as of December 31,
2016.  Please address the collateral on these receivables and if this factored into
the lack of allowance for credit losses.

Note 11 – Equity, page 113

4. Please tell us how you have complied with the disclosure requirements of ASC
Topic 718 -10-50-2.

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.

J. Brendan Herron
Hannon Armstrong Sustainable Infrastructure Capital, Inc.
June 26, 2017
Page 3

 You may contact Babette Cooper,  Staff Accountant, at 202 -551-3396  or me at
202-551-3438 if you have questions regarding comments on the financial statements and
related matters.  Please contact Staff Attorney at 202 -551-3438  with any other  questions.

Sincerely,

/s/ Robert Telewicz

Robert Telewicz, Jr.
Accounting Branch Chief
Office of Real Estate and
Commodities