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 March 17, 2026

James G. Dempsey
Chief Executive Officer, President and Director
Frontier Group Holdings, Inc.
4545 Airport Way
Denver, CO 80239

 Re: Frontier Group Holdings, Inc.
 Form 10-K for the Fiscal Year ended December 31, 2025
 Filed February 18, 2026
 File No. 001-40304
Dear James G. Dempsey:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2025
Financial Statements
Note 1 - Summary of Significant Accounting Policies
Cash and Cash Equivalents, page 94

1. We note your disclosure indicating that you consider all highly liquid
investments with
 original maturities of three months or less at the date of acquisition
to be cash and cash
 equivalents, although also indicating that items with maturities
greater than three
 months that are readily convertible to known amounts of cash
(including money market
 funds and time deposits) are also reported as cash and cash equivalents.

 As the definition of cash equivalents in FASB ASC 230-10-20 stipulates
that only
 investments with original maturities of three months or less qualify
under the definition,
 i.e. short-term, highly liquid investments that are readily convertible
to known amounts
 of cash, and so near their maturity that they present insignificant risk
of changes in value
 because of changes in interest rates, unless you are able to show why
this criteria would
 not apply to you (also considering the FASB deliberations regarding the
limit as
 March 17, 2026
Page 2

 documented in their basis for conclusions), it appears that the
instruments having original
 maturities greater than ninety days should be reclassified.

 Please provide us with details of the amounts that you have reported as
of the end of the
 two last fiscal years as cash and cash equivalents that did not have
maturities of three
 months or less when acquired.

Note 8 - Operating Leases
Aircraft Rent Expense and Maintenance Obligations, page 108

2. We note that you report aircraft lease extensions in each period which
impact your
 accruals for the right-of-use asset and corresponding liability,
although which also yield
 reductions to aircraft rent due to changes in estimates for lease
termination costs. Your
 accounting policy disclosure explains that some leases with initial
terms greater than
 12 months include rental escalation clauses, renewal options,
termination options and/or
 other items that cause variability and are factored into the
determination of lease
 payments when appropriate, although does not indicate how these
assessments are based
 on or utilize the criteria of exercise being reasonably certain to
occur.

 Please expand your accounting policy disclosure on page 95 and the
critical accounting
 policy disclosure on page 79 to describe the factors that you consider
in determining
 whether exercise of lease extension options are reasonably certain upon
entering into a
 lease, based on the guidance in FASB ASC 842-10-30-2 and 842-10-55-26,
and to
 explain how the prospects of exercise are reassessed in subsequent
periods based on the
 guidance in FASB ASC 842-10-35-1 and 842-10-55-28 and 29.

 Please include details sufficient to understand the alternatives to
exercise that are under
 consideration, and the nature of the changes in circumstances that
appear to arise only
 upon exercise and which do not result in any changes to your assessment
of exercise as
 being not reasonably certain in the intervening periods prior to
exercise. Please describe
 any correlation between your decisions to extend aircraft leases and any
changes in
 your plans to acquire aircraft as represented by the tabulation on page
77.

 Also tell us how many aircraft were covered by your lease extensions
each period, the
 number of years covered by the extensions exercised, and whether the
leases for the
 aircraft covered by those extensions had been subject to any prior
extensions and if so,
 also describe to us the typical terms for the initial lease periods,
terms for any extensions,
 and indicate whether there are typically multiple extensions available.

 In closing, 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 Yolanda Guobadia at 202-551-3562 or Gus Rodriguez at
202-551-3752
with any questions.
 March 17, 2026
Page 3

 Sincerely,

 Division of Corporation Finance
 Office of Energy & Transportation
cc: Tony Richmond
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