September 5, 2019

Frank Burkhartsmeyer
Chief Financial Officer
Northwest Natural Holding Co
220 N.W. Second Avenue
Portland, Oregon 97209

       Re: Northwest Natural Holding Co
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 1, 2019
           File No. 001-38681

Dear Mr. Burkhartsmeyer:

      We have reviewed your filing and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your
disclosure.

       Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.

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

Form 10-K for the Fiscal Year Ended December 31, 2018

Consolidated Statements of Shareholders' Equity, page 70

1.    We note the line item cash purchase of shares for business combination
here, and in the
      financing section of the statement of cash flows. Please tell us which
business
      combination these amounts relate to and the basis in GAAP for your
accounting. Please
      ensure your response addresses why an adjustment to common stock was
necessary. If
      amounts relate to the purchase of your own common stock, please tell us
why you did not
      describe amounts as treasury stock transactions.
        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 Tony Watson (Staff Accountant) at (202) 551-3318 or
Bill Thompson
(Accounting Branch Chief) at (202) 551-3344 if you have questions regarding
comments on the
financial statements and related matters. Please contact Katherine Bagley
(Staff Attorney) at
 Frank Burkhartsmeyer
Northwest Natural Holding Co
September 5, 2019
Page 2

(202) 551-2545 or Jacqueline Kaufman (Staff Attorney) at (202) 551-3797 with
any other
questions.



FirstName LastNameFrank Burkhartsmeyer                   Sincerely,
Comapany NameNorthwest Natural Holding Co
                                                         Division of
Corporation Finance
September 5, 2019 Page 2                                 Office of Consumer
Products
FirstName LastName