United States securities and exchange commission logo

                              September 7, 2022

       Gerald Laderman
       Executive Vice President and Chief Financial Officer
       United Airlines Holdings, Inc.
       233 South Wacker Drive
       Chicago, IL 60606

                                                        Re: United Airlines
Holdings, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed February 18,
                                                            File No. 001-06033

       Dear Mr. Laderman:

              We have reviewed your filing 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

              Please respond to these comments 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 our
       comments apply to your facts and circumstances, please tell us why in
your response.

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

       Form 10-K for Fiscal Year Ended December 31, 2021


   1.                                                   We note that you
provided more expansive disclosure in your Corporate Responsibility
                                                        Report than you
provided in your SEC filings. Please advise us what consideration you
                                                        gave to providing the
same type of climate-related disclosure in your SEC filings as you
                                                        provided in you
Corporate Responsibility Report.
   2.                                                   Disclosure is provided
in your Form 10-K regarding the company   s pledge    to become
                                                        100% green by
eliminating its greenhouse gas (   GHG   ) emissions by 2050 without relying
                                                        on the use of
traditional carbon offsets, the only airline globally to make this
                                                        commitment.    Please
describe your basis for identifying yourself as the only airline to
                                                        make this type of
commitment along with other statements such as describing yourself as
                                                           the largest airline
to invest in zero-emission engines for regional aircraft.    In addition,
                                                        clarify your definition
of the term    100% green.
 Gerald Laderman
FirstName  LastNameGerald   Laderman
United Airlines Holdings, Inc.
Comapany 7,
September  NameUnited
              2022      Airlines Holdings, Inc.
Page 2     7, 2022 Page 2
FirstName LastName
Risk Factors, page 18

3.       Please revise to disclose the material effects of transition risks
related to climate change
         that may affect your business, financial condition, and results of
operations, such as
         market trends that may alter business opportunities, credit risks, or
technological changes.
4.       Disclose any material litigation risks related to climate change and
explain the potential
         impact to the company.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page

5.       We note your disclosures on pages 8 and 28 regarding your capital
expenditures for
         climate-related projects. Please tell us about and quantify capital
expenditures for climate-
         related projects for each of the years covered by your Form 10-K and
any amounts
         budgeted for future periods.
6.       To the extent material, discuss the indirect consequences of
climate-related regulation or
         business trends, such as the following:
             decreased demand for services that produce significant greenhouse
gas emissions or
             are related to carbon-based energy sources;
             increased demand for goods that result in lower emissions than
competing products;
             increased competition to develop innovative new products that
result in lower
             increased demand for generation and transmission of energy from
alternative energy
             sources; and
             any anticipated reputational risks resulting from operations or
products that produce
             material greenhouse gas emissions.
7.       We note page 28 of your Form 10-K describes substantial costs and
         disruptions as a result of severe weather events caused by climate
change. If material,
         please discuss the physical effects of climate change on your
operations and results in
         greater detail. This disclosure may include:
             quantification of material weather-related damages to your
property or operations;
             potential for indirect weather-related impacts that have affected
or may affect your
              major suppliers; and
             any weather-related impacts on the cost or availability of
         Your response should include quantitative information for each of the
periods covered by
         your Form 10-K and explain whether changes are expected in future
periods, as
8.       We note your disclosure on page 28 regarding compliance costs related
to climate
         change. Please quantify any compliance costs for each of the periods
covered by your
         Form 10-K as well as any expected future costs.
9.       We note your disclosure on page 9 regarding carbon offsets purchased
in 2019 and 2020.
         Please quantify for us the amounts expended to purchase these offsets.
 Gerald Laderman
United Airlines Holdings, Inc.
September 7, 2022
Page 3

        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.

       You may contact Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.

FirstName LastNameGerald Laderman
                                                          Division of
Corporation Finance
Comapany NameUnited Airlines Holdings, Inc.
                                                          Office of Energy &
September 7, 2022 Page 3
cc:       Anna Ha
FirstName LastName