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      November 27, 2024

      VIA EDGAR

      Blaise Rhodes and Rufus Decker

      Division of Corporation Finance

      Office of Trade & Services

      U.S. Securities and Exchange Commission

      100 F Street, NE

      Washington, DC 20549-4631

                  Re:

                  FTAI Aviation Ltd.

      Form 10-K for Fiscal Year Ended December 31, 2023

      Item 2.02 Form 8-K filed July 24, 2024

      File No. 001-37386

      Dear Messrs. Rhodes and Decker,

      On behalf of FTAI Aviation Ltd. (the “Company” or “FTAI”), the undersigned submits this letter in response to a comment from the staff (the “Staff”) of the U.S. Securities and
        Exchange Commission (the “Commission”) received by letter, dated November 5, 2024 (the “Comment Letter”), relating to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2023 (the “10-K”) and Item 2.02 of Form 8-K filed
        July 24, 2024 (the “8-K”). To facilitate your review, the undersigned has reproduced the text of the Staff’s comment in italics below, and the heading and comment number in this letter correspond to the heading and comment number in the Comment
        Letter. In addition, capitalized terms used but not defined herein shall have the meanings assigned to such terms in the 10-K and 8-K, as applicable.

      Form 10-K for Fiscal Year Ended December 31, 2023

      Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 32

            1.

              Please substantially revise both your consolidated and segment results of operations discussions to disclose in greater detail the underlying business reasons for material changes between
                periods in each line item. In circumstances where there are more than one underlying business reason for the change, quantify the incremental impact of each individual reason discussed on the overall change in the line item. Refer to Item
                303 of Regulation S-K.

      Response

      The Company respectfully acknowledges the Staff’s comment. In future quarterly and annual reports, for all periods presented, the Company confirms that it will disclose in greater detail the underlying
        business reasons for material changes between periods in each line item and, in circumstances where there are two or more underlying business reasons for such material changes, will quantify the incremental impact of each factor. The Company has
        included additional qualitative and quantitative disclosure in its Form 10-Q for the quarter ended September 30, 2024, filed on November 12, 2024. See Item 2. Management’s Discussion and Analysis of
        Financial Condition and Results of Operations on pages 37-50.

      Consolidated Balance Sheets, page 53

            2.

              Please disclose total current assets and total current liabilities for all periods presented. Refer to Rules 5-02.9 and .21 of Regulation S-X.

            Messrs. Blaise Rhodes and Rufus Decker

            U.S. Securities and Exchange Commission

            November 27, 2024

            Page 2

      Response

      The Company respectfully acknowledges the Staff’s comment and will disclose total current assets and total current liabilities for all periods presented in the Consolidated Balance Sheets beginning with
        its Form 10-K filing for the year ended December 31, 2024.

      Consolidated Statements of Operations, page 54

            3.

              Please present cost of tangible goods sold, expenses applicable to rental income, cost of services and expenses applicable to other revenues separately. Refer to Rule 5-03.2 of Regulation S-X.

      Response

      The Company respectfully acknowledges the Staff’s comment. Cost of sales is primarily comprised of the net book values of leasing equipment sold and cost of inventory sold.  The expenses applicable to rental income are
        immaterial for separate disclosure for the years ended December 31, 2023, 2022 and 2021.  We had no cost of services in the periods presented. The significant cost associated with lease income is the depreciation of leasing equipment.  This cost is
        included in depreciation and amortization, which is separately shown on the Statements of Operations.  In future filings, the Company will indicate that cost of sales excludes depreciation and amortization.

      The Company will continue to monitor the materiality of expenses applicable to rental income and the cost of services and, if material, update the Statements of Operations in accordance
          with Rule 5-03.2 of Regulation S-X.

            4.

              Please include gain on sale of assets, net in the same area of the statements of operations as your operating items. Also, include interest expense in the same area of the statements of
                operations as your non-operating items. Refer to Rules 5-03.3 through .9 of Regulation S-X and ASC 360-10-45-5.

      Response

      The Company respectfully acknowledges the Staff’s comment and will update the presentation of the Statements of Operations in all future filings, beginning with its Form 10-K filing for the year ended
        December 31, 2024, to show gain on sale of assets, net in the same area as its other operating items within the Total expenses line. Additionally, the Company updated the presentation of the Statements of Operations in its Form 10-Q filing for the
        quarter ended September 30, 2024 that was filed on November 12, 2024, to show interest expense in the same area as its other income (expense) line items and will continue to do so in all future filings.

      Consolidated Statements of Cash Flows, page 58

            5.

              Please disclose in greater detail the nature of each non-cash activity shown in the supplemental disclosures. The revised disclosures should clearly discuss both sides of the non-cash
                transactions, so that it is transparent why the transactions are non-cash. For the transfers from leasing equipment, please also disclose the asset category to which the transfers were made and the circumstances surrounding the transfers.
                Also, tell us whether these assets were still under lease at the time of transfer and quantify the amounts for each period presented. Next, tell us and disclose whether the later cash inflows from the sale/disposition of leasing equipment
                transferred to inventory are included in investing activities or operating activities. If these later cash inflows are not included in investing activities, explain in detail how your inconsistent classification for the cash outflows and
                cash inflows complies with GAAP. For all cash inflows included in operating activities related to leasing equipment transferred to inventory, tell us the amounts for each period presented, including 2024 interim periods. If there have been
                transfers from inventory to leasing equipment or other long-lived assets, provide revised disclosures presenting this non-cash activity separately and include a similar GAAP analysis with quantification of cash inflows included in investing
                activities related the sale/disposition of inventory transferred to leasing equipment or other long-lived assets. Finally, disclose in a footnote your accounting policy for cash inflows and cash outflows related to each category of
                transferred assets (before transfer and after transfer). Refer to ASCs 230-10-45-22 and 45-22A.

            Messrs. Blaise Rhodes and Rufus Decker

            U.S. Securities and Exchange Commission

            November 27, 2024

            Page 3

      Response: The Company respectfully acknowledges the Staff’s comment. For purposes of responding to the different components of the comment, the Company has separated its response into five sections:

            a)

              Non-cash activity in the supplemental disclosures

            b)

              Background and accounting policy for transfers of engines from leasing equipment to inventory

            c)

              Background and accounting policy for transfers of modules and parts from inventory to leasing equipment

            d)

              Quantification of the requested amounts by reporting period

            e)

              Financial statement disclosures

                (a)

                Non-cash activity in the supplemental disclosures

      Included below is an excerpt from the Company’s Form 10-K for the year ended December 31, 2023 (“2023 Form 10-K”) specific to supplemental disclosures of non-cash investing and financing. The
        material components are explained in greater detail below.  Please see (e) below for clarifying disclosures the Company plans to provide in future filings.

              Supplemental disclosure of non-cash investing

              and financing activities as disclosed in the 2023

               Form 10-K: (in thousands)

              Note

              Year ended

              December

              31, 2021

              Year ended

              December

               31, 2022

              Year ended

              December

              31, 2023

              Acquisition of leasing equipment

            A

              $

              (44,552

              )

              $

              (74,706

              )

              $

              (105,313

              )

              Acquisition of property, plant and equipment

              Immaterial*

              (581

              )

              -

              (699

              )

              Transfers from leasing equipment

            B

              91,266

              121,855

              224,218

              Security deposits, maintenance deposits, other assets and other liabilities settled in the sale of leasing equipment

            C

              400

              18,385

              24,116

              Settled and assumed security deposits

            D

              (4,041

              )

              (6,774

              )

              823

              Billed, assumed and settled maintenance deposits

            E

              (21,710

              )

              (47,933

              )

              (18,907

              )

              Non-cash change in equity method investment

            F

              (129,907

              )

              (182,963

              )

              -

              Conversion of interests in unconsolidated entities

            G

              -

              (21,302

              )

              -

              Issuance of ordinary shares

              Immaterial*

              455

              399

              924

      * The Company intends to remove these immaterial amounts in its disclosures in the 2024 Form 10-K

                  (A)

                  Acquisition of leasing equipment includes the following material activities (Note 1):

                  -

                  Receipt of leasing equipment, unrelated to the Company’s leasing equipment under lease, in lieu of cash payment to settle outstanding receivables due from lessees

            -

              Acquisition of leasing equipment in accrued liabilities

            -

              Purchase deposits reclassified to leasing equipment from other assets upon acquisition

            (B)

              Transfers from leasing equipment includes the following material activities:

            -

              Transfers from leasing equipment to inventory for the teardown of engines (with the intent to manufacture new assets for sale as further discussed below), offset by transfers from inventory to leasing equipment
                for modules and parts used to rebuild full engines. Refer to sections (b) and (c) of our response below for further detail and explanation of our accounting policies and section (e) of our response below for further detail on revised
                disclosures, including presentation of this activity on a gross basis in future filings

            Messrs. Blaise Rhodes and Rufus Decker

            U.S. Securities and Exchange Commission

            November 27, 2024

            Page 4

              -

                Engine exchanges provided to aircraft lessees in lieu of cash reimbursements of maintenance deposits

                -

                  Receipt of notes receivable from customers in connection with the sale of leasing equipment. Cash received under the notes receivable is recorded as an inflow within net cash used in investing activities

            (C)

              Security deposits, maintenance deposits, other assets and other liabilities settled in the sale of leasing equipment with customers (Note 1)

            (D)

              Settled and assumed security deposits includes the following activities (Note 1):

            -

              Decrease in security deposit liabilities when used to settle outstanding receivables due from lessees

            (E)

              Billed, assumed and settled maintenance deposits includes the following activities (Note 1):

            -

              Decrease in maintenance deposits resulting from engine exchanges provided to lessees in lieu of cash reimbursements

            -

              Decrease in maintenance deposit liabilities when used to settle outstanding receivables due from lessees

            -

              Decrease in maintenance deposits related to non-recurring events associated with Russia and Ukraine, as disclosed in Footnote 4 of the 2022 Form 10-K

            (F)

              Non-cash change in equity method investment includes:

            -

              Changes in equity method investment related to the change in the fair value of non-hedge derivatives held by the equity method investment (included in discontinued operations)

            (G)

              Conversion of interests in unconsolidated entities includes:

            -

              Conversion of equity and credit agreements into new equity interests of unconsolidated entities (included in discontinued operations)

      Note 1 (amounts in thousands) – Within the 2023 Form 10-K, these non-cash line items also included certain activity associated with the acquisition and disposal of leasing equipment. The Company
        removed this activity, primarily related to maintenance and security deposit liabilities, from the change in the relevant financial statement line items and included the activity on the line items above in its cash flow presentation. The cash paid
        for acquisitions is included in “Acquisition of leasing equipment” and the cash received for the sale of assets is included in “Proceeds from sale of leasing equipment”. For acquisitions, maintenance and security deposit liabilities assumed were
        $24,506, $49,545 and $40,530 for the years ended December 31, 2021, 2022 and 2023, respectively. For disposals, maintenance and security deposit liabilities derecognized were $(218), $(25,540) and $(10,282) for the years ended December 31, 2021,
        2022 and 2023, respectively. In all future filings, beginning with the 2024 Form 10-K, the Company intends to disclose this activity within its leasing equipment footnote (FN5 in 2023 Form 10-K).

                      (b)

                      Transfers of engines from leasing equipment to inventory

        Transfers of engines from leasing equipment to inventory are only made when the engines are not on lease. The Company’s aerospace products business focuses on the manufacturing and sale of new assets through the use of inventory purchased from third parties and salvaged modules and parts from generally unserviceable
              engines.