Exhibit 25.1


================================================================================

                       SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D.C. 20549

                           --------------------------

                                    FORM T-1

                         STATEMENT OF ELIGIBILITY UNDER
                      THE TRUST INDENTURE ACT OF 1939 OF A
                    CORPORATION DESIGNATED TO ACT AS TRUSTEE
              Check if an Application to Determine Eligibility of
                    a Trustee Pursuant to Section 305(b)(2)
            -------------------------------------------------------

                         U.S. BANK NATIONAL ASSOCIATION
              (Exact name of Trustee as specified in its charter)

                                   31-0841368
                       I.R.S. Employer Identification No.

             180 East Fifth Street
              St. Paul, Minnesota                                55101
   (Address of principal executive offices)                    (Zip Code)

                                 Julie Balerna
                         U.S. Bank National Association
                               One Federal Street
                                Boston, MA 02110
                                 (617) 603-6565

           (Name, address and telephone number of agent for service)

                             ALASKA AIR GROUP, INC.
            (exact name of Registrant as Specified in it's charter)

DELAWARE                                       34-1697351
(State or other jurisdiction of                (IRS Employer Identification No.)
incorporation or organization)

19300 PACIFIC HIGHWAY SOUTH
SEATTLE, WA                                    98188
(Address of principal executive offices)       (Zip Code)

            ALASKA AIR GROUP, INC. SENIOR CONVERTIBLE NOTES DUE 2023
                      (Title of the Indenture Securities)

                                    FORM T-1


ITEM 1.     GENERAL INFORMATION. Furnish the following information as to the
            Trustee.

            a)    Name and address of each examining or supervising authority to
                  which it is subject.
                        Comptroller of the Currency
                        Washington, D.C.

            b)    Whether it is authorized to exercise corporate trust powers.
                        Yes

ITEM 2.     AFFILIATIONS WITH OBLIGOR. If the obligor is an affiliate of the
            Trustee, describe each such affiliation.

                  None

ITEMS 3-15  Items 3-15 are not applicable because to the best of the Trustee's
            knowledge, the obligor is not in default under any Indenture for
            which the Trustee acts as Trustee.

ITEM 16.    LIST OF EXHIBITS: List below all exhibits filed as a part of this
            statement of eligibility and qualification.

            1.    A copy of the Articles of Association of the Trustee.*

            2.    A copy of the certificate of authority of the Trustee to
                  commence business.*

            3.    A copy of the certificate of authority of the Trustee to
                  exercise corporate trust powers.*

            4.    A copy of the existing bylaws of the Trustee.*

            5.    A copy of each Indenture referred to in Item 4. Not
                  applicable.

            6.    The consent of the Trustee required by Section 321(b) of the
                  Trust Indenture Act of 1939, attached as Exhibit 6.

            7.    Report of Condition of the Trustee as of MARCH 31, 2003,
                  published pursuant to law or the requirements of its
                  supervising or examining authority, attached as Exhibit 7.

      * Incorporated by reference to Registration Number 333-67188.


                                       2

                                      NOTE

      The answers to this statement insofar as such answers relate to what
persons have been underwriters for any securities of the obligors within three
years prior to the date of filing this statement, or what persons are owners of
10% or more of the voting securities of the obligors, or affiliates, are based
upon information furnished to the Trustee by the obligors. While the Trustee has
no reason to doubt the accuracy of any such information, it cannot accept any
responsibility therefor.

                                    SIGNATURE

      Pursuant to the requirements of the Trust Indenture Act of 1939, as
amended, the Trustee, U.S. BANK NATIONAL ASSOCIATION, a national banking
association organized and existing under the laws of the United States of
America, has duly caused this statement of eligibility and qualification to be
signed on its behalf by the undersigned, thereunto duly authorized, all in the
City of Boston, Commonwealth of Massachusetts on the 17TH DAY OF JULY 2003.

                                         U.S. BANK NATIONAL ASSOCIATION

                                         By:   /s/ JULIE A. BALERNA
                                               ---------------------------------
                                               JULIE A. BALERNA
                                               ASSISTANT VICE PRESIDENT


                                       3

                                   EXHIBIT 6

                                    CONSENT

      In accordance with Section 321(b) of the Trust Indenture Act of 1939, the
undersigned, U.S. BANK NATIONAL ASSOCIATION hereby consents that reports of
examination of the undersigned by Federal, State, Territorial or District
authorities may be furnished by such authorities to the Securities and Exchange
Commission upon its request therefor.

Dated: July 17, 2003


                                      U.S. BANK NATIONAL ASSOCIATION


                                      BY:   /S/ JULIE A. BALERNA
                                            ------------------------------------
                                            JULIE A. BALERNA
                                            ASSISTANT VICE PRESIDENT


                                       4

                                   EXHIBIT 7
                         U.S. BANK NATIONAL ASSOCIATION
                        STATEMENT OF FINANCIAL CONDITION
                                AS OF 3/31/2003

                                    ($000'S)



                                                                     3/31/2003
                                                                   -------------
                                                                
ASSETS
     Cash and Due From Depository Institutions                        $9,084,839
     Federal Reserve Stock                                                     0
     Securities                                                       30,038,992
     Federal Funds                                                       833,567
     Loans & Lease Financing Receivables                             112,792,313
     Fixed Assets                                                      1,462,006
     Intangible Assets                                                 9,080,815
     Other Assets                                                     10,317,239
                                                                   -------------
         TOTAL ASSETS                                               $173,609,771

LIABILITIES
     Deposits                                                       $121,508,878
     Fed Funds                                                         3,820,981
     Treasury Demand Notes                                                     0
     Trading Liabilities                                                 454,575
     Other Borrowed Money                                             21,082,000
     Acceptances                                                         139,821
     Subordinated Notes and Debentures                                 5,694,952
     Other Liabilities                                                 5,164,656
                                                                   -------------
     TOTAL LIABILITIES                                              $157,865,863

EQUITY
     Minority Interest in Subsidiaries                                  $993,907
     Common and Preferred Stock                                           18,200
     Surplus                                                          11,015,123
     Undivided Profits                                                 7,438,448
                                                                   -------------
         TOTAL EQUITY CAPITAL                                        $19,465,678

TOTAL LIABILITIES AND EQUITY CAPITAL                                $177,331,541



                                       5