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                            March 6, 2024

       Tammy Romo
       Chief Financial Officer
       Southwest Airlines Co.
       P.O. Box 36611
       Dallas, Texas 75235

                                                        Re: Southwest Airlines
Co.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2023
                                                            Filed February 6,
2024
                                                            File No. 001-07259

       Dear Tammy Romo:

              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, 2023

       Management's Discussion and Analysis
       Operating Revenues, page 68

   1.                                                   We note that you
provide disclosure in the third paragraph on page 3, explaining that
                                                        "Business travel, while
showing modest improvements over several years, remained at
                                                        reduced levels
throughout 2022 and 2023 compared with pre-pandemic levels, as
                                                        corporate travel
patterns continued to lag and evolve post-pandemic." We also see that
                                                        you discuss initiatives
aimed at growing the corporate travel business on page 12, and
                                                        discuss some of the
associated risk on page 32.

                                                        Please expand your
discussion and analysis of revenue and passenger levels as necessary
                                                        to clarify the
significance of this business, and to address the implications of the
                                                        respective trends to
comply with Item 303(a) and (b)(2) of Regulation S-K.
 Tammy Romo
Southwest Airlines Co.
March 6, 2024
Page 2
Financial Statements
Note 1. Summary of Significant Accounting Policies
Property & Equipment, page 95

2.       We understand from your disclosure that you estimate the useful life
of flight equipment
         at 25 years, and associated residual values that range from 13% to 20%

         Please explain to us how you established the useful lives and residual
values of your
         aircraft, and describe any efforts undertaken to revisit and update
these policies on a
         regular basis. For example, given your disclosure on page 52, that you
own 736 Boeing
         737 aircraft, tell us how you considered the potential effect on
marketability of used
         aircraft that were subject to the FAA grounding discussed on page 42,
to address
         manufacturing and safety concerns, in estimating residual values and
disposal costs.

         In conjunction with your response, please submit a summary of aircraft
sales over the last
         three years, in the form of a spreadsheet specifying the type of each
aircraft and showing
         for each the acquisition dates and costs, your estimate of the useful
lives and residual
         values, the useful life and residual value percentage applied, the
accumulated depreciation
         and net book values on the disposal dates, the disposal dates and
costs and proceeds
         received in exchange, and the net gain or loss on each transaction.

         Please provide us with an explanation for how the residual value
percentage applied was
         correlated with the aircraft, and discuss any material variances
between the residual values
         that had been calculated and the net of disposal costs and proceeds.
       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 Robert Babula at 202-551-3339 or Gus Rodriguez at
202-551-3752 with
any questions.



FirstName LastNameTammy Romo                                   Sincerely,
Comapany NameSouthwest Airlines Co.
                                                               Division of
Corporation Finance
March 6, 2024 Page 2                                           Office of Energy
& Transportation
FirstName LastName