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                              September 21, 2021

       Jason Aiken
       Chief Financial Officer
       General Dynamics Corporation
       11011 Sunset Hills Road
       Reston, Virginia 20190

                                                        Re: General Dynamics
Corporation
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2020
                                                            Filed February 9,
2021
                                                            File No. 001-03671

       Dear Mr. Aiken:

              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
       disclosure.

              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.

   1.                                                   There have been
significant developments in federal and state legislation and regulation
                                                        and international
accords regarding climate change. We note that you have not discussed
                                                        the impact of pending
or existing climate change-related legislation, regulations, and
                                                        international accords
in your SEC filing. Please revise your disclosure to identify material
                                                        existing climate
change-related legislation, regulations, and international accords and any
                                                        material effect on your
business, financial condition, and results of operations.

   2.                                                   We note that you refer
to several climate-related projects in your CSR report. Please
                                                        revise your disclosure
to identify any material past and/or future capital expenditures for
                                                        climate-related
projects. If material, please quantify these expenditures.

   3.                                                   To the extent material,
discuss the indirect consequences of climate-related regulation or
                                                        business trends, such
as the following:
                                                            decreased demand
for goods or services that produce significant greenhouse gas
                                                            emissions or are
related to carbon-based energy sources;
 Jason Aiken
General Dynamics Corporation
September 21, 2021
Page 2
                increased demand for goods that result in lower emissions than
competing products;
                increased competition to develop innovative new products that
result in lower
              emissions; and
                any anticipated reputational risks resulting from operations or
products that produce
              material greenhouse gas emissions.
4.       If material, discuss the significant physical effects of climate
change on your operations
         and results. This disclosure may include the following:
             severity of weather, such as floods, hurricanes, sea levels,
extreme fires, and water
             availability and quality;
             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 customers or suppliers; and
             any weather-related impacts on the cost or availability of
insurance.
5.       Disclose the material effects of transition risks related to climate
change that may affect
         your business, financial condition, and results of operations, such as
policy and regulatory
         changes that could impose operational and compliance burdens, market
trends that may
         alter business opportunities, credit risks, or technological changes
6.       Disclose any material litigation risks related to climate change and
the potential impact to
         the company.
7.       If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
         any material effects on your business, financial condition, and
results of operations.
        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 Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding the
comments.



FirstName LastNameJason Aiken                                  Sincerely,
Comapany NameGeneral Dynamics Corporation
                                                               Division of
Corporation Finance
September 21, 2021 Page 2                                      Office of
Manufacturing
FirstName LastName