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Response Letter

 July 11, 2017

VIA EDGAR

 Ms. Babette Cooper

Mr. Robert Telewicz, Jr.

 United States Securities and
Exchange Commission

 Division of Corporation Finance

 Attn:
Robert Telewicz, Jr.

 100 F Street, N.E.

 Washington, D.C.
20549-0306

 Re: Hannon Armstrong Sustainable Infrastructure Capital, Inc.

Form 10-K for Fiscal Year Ended

December 31, 2016

Filed February 24, 2017

File No. 001-35877

 Dear
Ms. Cooper and Mr. Telewicz:

 On behalf of Hannon Armstrong Sustainable Infrastructure Capital, Inc., (the “Company”,
“we” or “our”), set forth below are the responses of the Company to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”),
received by letter dated June 26, 2017 (the “June 26 Letter”), with respect to the Company’s Form 10-K for the year ended December 31, 2016 (the “Form 10-K”). The responses to the Staff’s comments are set out
in the order in which the comments were set out in the June 26 Letter and are numbered accordingly.

 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 constant yield. We
further note this methodology 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.

 We believe
that our core earnings measure for our equity method investments is a useful supplemental performance measure to our investors. We have historically utilized this measure in a consistent manner and reevaluated its calculation and use when the
updated C&DI regarding Non-GAAP measures, including question 100.04, was released by the SEC. Based on our reevaluation, we did not, and do not, believe we are substituting a tailored recognition and measurement method for US GAAP. Rather,
we are providing supplemental information to investors to assist in evaluating the return on, and the return of, the capital invested in our equity investment that is not located elsewhere in our filings. Without access to this information,
investors may have difficulty evaluating the economic performance of invested capital. We also do not believe it is a misleading adjustment under Rule 100(b) as based on discussions with numerous investors, they typically understand the concept and
the calculation, and utilize it in their investment analysis.

 1906 Towne Centre Blvd., Suite 370

Annapolis, MD 21401

 410 - 571 -
9860

 www.hannonarmstrong.com

 We focus on yield oriented investments with predictable cash flows and our two
largest areas of investment are financing receivables and equity method investments. In both cases, we purchase the investment based on the net present value of the expected cash flows and a discount rate, or the investment rate. Investors, in
part, evaluate us based upon our ability to achieve an appropriate risk adjusted investment rate for particular assets. In regards to financing receivables, the interest or investment income earned is located on the income statement, (the
return on the capital) and the amount of principal repayments in the cash flow statement, (the return of capital) and thus investors can evaluate the investment rate by comparing the investment income to the average balance of financing
receivables.

 However, in regards to our equity method investments, the cash distributions for our equity method
investments are segregated into a return on and return of capital on the cash flow statement. This allocation is determined, in part, on the cumulative income that has been allocated using the hypothetical liquidation at book value (HLBV) method.
However, as explained in more detail below, the HLBV income allocations alone may not convey the economic returns (i.e. return on capital) achieved from the investment and we believe our core earnings measure is an important supplement to the HLBV
income allocations determined under US GAAP for an investor to understand the economic performance of these investments. We provide a calculation of the return on capital as a supplemental performance measure based upon the investment rate on
the asset as adjusted for the actual performance of the project and the cash distributed. The adjustment to the initial investment rate results in the rate of return on capital being presented reflecting the performance of the project. This
supplemental calculation allows investors to evaluate the performance of our equity method investments in a manner consistent with our other investments. From our discussions with investors, they believe it is a useful measure of our performance as
it allows a comparative evaluation of economic performance across various asset classes.

 By way of background, we make
equity investments in renewable energy projects (the “projects”) where typically, the income and cash allocations to us change over time in what is commonly referred to as a partnership “flip structure” or a “tax equity flip
structure.” Institutional investors in these structures are seeking a return on capital from either cash or tax attributes (i.e. tax credits and tax depreciation) or a combination of both. The investors that invest solely for the tax attributes
are referred to as tax equity investors. In contrast, our business strategy is to invest in the contracted cash flows of these projects which is a function of our desire and requirement to pay cash dividends to our stockholders. The projects
typically have a high level of contracted revenue, predictable energy output and no debt which produces a predictable rate of return over the life of the investment. In many of these projects, the allocation of cash (which our investment is
based upon) is significantly different than the allocation of income (which is also how tax attributes are allocated and thus what the tax equity investor is interested in). For example, we may initially receive 90% of the cash but only a 5%
allocation of the income. Under the negotiated structure, these allocations will later change (i.e. flip) with most of the cash and the income being allocated to the sponsor.

Due to the variable nature of the allocations discussed above (i.e. existence of a substantive profit-sharing arrangement), it
is industry practice to calculate equity method income allocations for these types of investments utilizing the HLBV method. Under the HLBV method, our allocation of income is largely determined by two items.

 2

a.
First, the tax equity investor is allocated losses in proportion to the tax attributes received, while the other investors are allocated income for similar amounts due to the change in each investors’ claim on the
net assets of the business. This occurs because the return calculation for the liquidation waterfall used for HLBV includes the value of the tax attributes received by the tax equity investor but the value of the tax attributes is not reflected in
assets, income or equity of the project. Thus a lower share of net assets is allocated to the tax equity investor, resulting in a GAAP loss in proportion to the tax attributes received. These income allocations to the tax equity investor are usually
in excess of the actual GAAP pre-tax income of the underlying projects since the allocation is driven based on the amount of tax benefits the tax equity investor is receiving and not just the GAAP pre-tax income of the project. The effect of this
accounting is large gains/losses are recognized in the earlier periods of the project as the tax attributes are received (e.g. up to ten years in the case of wind projects as production tax credits and accelerated tax depreciation are realized).

b.
Secondly, the allocation of profit and loss may vary significantly under the flip structure and often the profit and loss does not have a relationship to the amount of cash that is allocated to a particular investor.

 In summary, although, the income allocations using the HLBV method depict the changes in claim on the net
assets of the business under US GAAP, we believe including a supplemental measure illustrating the economic performance of the investment using factors we evaluate as part of assessing our investment performance (i.e. the rate of return, and
timing of cash flows) is useful to an investor.

 Additionally, we use our calculation of core earnings to determine the
return on capital that we can distribute to our investors. Given the nature of our structure as a REIT and the nature of our renewable energy project investments, investors in our industry view yield based metrics as being a standard
supplemental metric and utilize this metric in comparing the performance of issuers in the industry. We, like many REITS, YieldCos and MLPs, pay out the majority of the cash received from projects, less capital necessary for reinvestment such as
capital expenditures, to investors in the form of quarterly dividends. Many of the participants in these sectors use FFO or Cash available for Distribution (“CAFD”) as a comparable measure.

As a portion of the cash received represents the return of rather than a return on the upfront capital, we believe it is
important to differentiate between the return on capital and the return of capital in order to not overstate the return on capital. This is also consistent with our initial investment thesis for these projects where we determine the purchase
price based on the net present value of the expected cashflows.

 Due to the nature of our organizational structure (i.e. a
REIT), we pay the majority of our core earnings as dividends to our stockholders. Refer below for our historical core earnings and dividends paid to stockholders.

 (in millions)

Dividends paid

Core Earnings

 2016

$
49

$
51

 2015

$
32

$
34

 2014

$
14

$
20

 In summary, we believe that our adjustments for our equity method investments is (a) not a
misleading adjustment and is an important supplemental measure (rather than a substitute tailored accounting principle) to US GAAP as it enables an investor to understand the portion of the return that is a return on capital, (b) it is
well understood by investors and important for them to understand the performance of our business, and (c) consistent with measures used by the companies to which we are often compared.

 3

 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 receivables 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.

 Our
loan/financing receivables consist of the following asset types:

12/31/16

 Loan receivables

$
1,013,900,782

 Direct financing leases

$
28,336,495

 Financing Receivables

$
1,042,237,277

 We evaluated Regulation S-X Rule 4-02, which states that “If the amount which would
otherwise be required to be shown with respect to any item is not material, it need not be separately set forth”. We did not believe the direct financing leases were material enough to separately present them from loan receivables as they were
only 2.7% of total financing receivables and 1.6% of reported total assets as of December 31, 2016. Additionally, we concluded that it was appropriate to aggregate the direct financing leases with the other loan receivables given that the
economic attributes of the instruments and their credit profile (government or government supported) were similar to our other financing receivables.

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 status as of December 31, 2016. Please address the collateral on these receivables and if this factored into the lack of allowance for credit losses.

Our classification of the assets as non-investment grade reflects ratings either by an independent third party rating service
or our internal credit rating system regarding the credit quality of the investment and an investment could be considered non-investment grade for a number of factors. It is not a measure of impairment by itself.

We separately evaluate each of our financing receivables including those that are considered non-investment grade, for
impairment based on the guidance in ASC 310-10-35-16. Our policy for impairment and placing a financing receivable on non-accrual status is disclosed in Note 2 to the Consolidated Financial Statements included in our 2016 Form 10-K and a relevant
excerpt is below;

 4

 “We evaluate our financing receivables for potential delinquency or
impairment on at least a quarterly basis and more frequently when economic or other conditions warrant such an evaluation. When a financing receivable becomes 90 days or more past due, and if we otherwise do not expect the debtor to be able to
service all of its debt or other obligations, we will generally consider the financing receivable delinquent or impaired and place the financing receivable on non-accrual status and cease recognizing income from that financing receivable
until the borrower has demonstrated the ability and intent to pay contractual amounts due. If a financing receivable’s status significantly improves regarding the debtor’s ability to service the debt or other obligations, we will remove it
from non-accrual status.

 A financing receivable is also considered impaired as of the date when, based on
current information and events, it is determined that it is probable that we will be unable to collect all amounts due in accordance with the original contracted terms. Many of our financing receivables are secured by energy efficiency and renewable
energy infrastructure projects. Accordingly, we regularly evaluate the extent and impact of any credit deterioration associated with the performance and value of the underlying project, as well as the financial and operating capability of the
borrower, its sponsors or the obligor as well as any guarantors. We consider a number of qualitative and quantitative factors in our assessment, including, as appropriate, a project’s operating results, loan-to-value ratios and any
cash reserves, the ability of expected cash from operations to cover the cash flow requirements currently and into the future, key terms of the transaction, the ability of the borrower to refinance the transaction, other credit support from the
sponsor or guarantor and the project’s collateral value. In addition, we consider the overall economic environment, the sustainable infrastructure sector, the effect of local, industry, and broader economic factors, the impact of any variation
in weather and the historical and anticipated trends in interest rates, defaults and loss severities for similar transactions.”

As of December 31, 2016, no conditions existed that would indicate that it was probable that amounts due in the future
would not be collected in accordance with the contractual terms of the agreement, including with respect to our n