October 24, 2007

Via U.S. Mail and Facsimile

Brian Dunne
Executive Vice-President and Chief Financial Officer
ACE Aviation Holdings Inc.
5100 de Maisonneuve Boulevard West
Montreal, Quebec, Canada H4A 3T2

RE:		ACE Aviation Holdings Inc.
      Form 40-F for Fiscal Year Ended December 30, 2006
      Filed March 30, 2007
      Form 6-K filed August 14, 2006
		File No. 0-51034

Dear Mr. Dunne:

      We have reviewed your response letter dated October 16,
2007,
and have the following comments.  We welcome any questions you may
have about our comments or on any other aspect of our review.
Feel
free to call us at the telephone numbers listed at the end of this
letter.

General
1. We note the representation in your response letter dated
October
16, 2007, that Air Canada Vacations offers a variety of leisure
vacation package options for Canadians to several countries and
regions of the world, including Asia.  In some lexicons, "Asia"
includes countries generally identified as part of the Middle
East,
including Iran and Syria.  Please advise us whether Air Canada
Vacations offers vacation packages to, and whether Air Canada
flies
to and from, Iran, North Korea, and Syria, which are countries
that
are identified as state sponsors of terrorism by the U.S.
Department
of State and subject to U.S. sanctions and export controls.  If
so,
provide us the same information and materiality analysis regarding
your contacts with those countries, individually and in the
aggregate, as we requested in our prior comments 1 and 2 regarding
your contacts with Cuba.
2. We note your response to our prior comment 2.  You address the
materiality of your Cuba-related operations only in terms of
quantitative factors and the legality of the operations.  Please
expand your materiality analysis to address the possibility that
your
Cuba-related operations may negatively impact your reputation and
share value, in light of the investor sentiment evidenced by the
various legislative and other initiatives cited as examples our
prior
comment.
* * * * *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Please file
your
response letter on EDGAR.

      Please understand that we may have additional comments after
we
review your response to our comments.  Please contact Pradip
Bhaumik,
Attorney-Advisor, at (202) 551-3333 if you have any questions
about
the comments or our review.  You may also contact me at (202) 551-
3470.


								Sincerely,



								Cecilia Blye, Chief
								Office of Global Security
Risk

cc: 	Christopher W. Morgan, Esq.
		Skadden, Arps, Slate, Meagher & Flom LLP
		Fax:  (416-777-4747)

		Max Webb
		Assistant Director
	Division of Corporation Finance







Brian Dunne
ACE Aviation Holdings Inc.
October 24, 2007
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