September 21, 2018

Scott Christopher
Chief Financial Officer
Fortress Transportation & Infrastructure Investors LLC
1345 Avenue of the Americas
New York, NY 10105

       Re: Fortress Transportation & Infrastructure Investors, LLC
           Form 10-Q for Fiscal Quarter Ended June 30, 2018
           Filed August 3, 2018
           Form 10-K for Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 001-37386

Dear Mr. Christopher:

       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.

Form 10-K for Fiscal Year Ended December 31, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Application of Critical Accounting Policies
Goodwill, page 87

1.    The goodwill critical accounting policy cites an increase in forecasted
revenue based on
      increased volumes under current contracts and the acquisition of
additional storage
      contracts, the expansion of refineries in the Beaumont/Port Arthur area,
growing crude oil
      production in the U.S. and Canada and the development of both inbound and
outbound
      pipelines to and from the Jefferson Terminal over the next two years.
Please provide us
      with your goodwill impairment analysis for this reporting unit as of your
most recent
 Scott Christopher
Fortress Transportation & Infrastructure Investors LLC
September 21, 2018
Page 2
         testing date. Please tell us how you considered actual historical
results pursuant to item d
         of ASC 350-20-35-3C. In this regard, we note the sequential decrease
of revenues during
         each of the quarters of 2017, along with increased net losses,
increased adjusted net losses,
         and increased negative adjusted EBITDA for Jefferson Terminal over
those periods. We
         note the losses continue into the two quarters of 2018.
Form 10-Q for Fiscal Quarter Ended June 30, 2018

Financial Statements
Note 2- Summary of Significant Accounting Policies
Revenue Recognition, page 13

2.       We note your disclosures on page 13 for the adoption of ASC 606, which
appear to
         substantially replicate the disclosures you provided in your 2017 Form
10-K in
         accordance with SAB 74 rather than the disclosures required by ASC
606-10-50. Please
         tell us how you considered the disclosure guidance set forth in ASC
606-10-50 for your
         revenue that is subject to ASC 606 (e.g. explanations of your
performance obligations,
         transaction price allocated to remaining performance obligations,
significant judgments
         applied, determining the timing of satisfaction of each performance
obligation, election of
         practical expedients, etc.). We remind you of the guidance in Rule
10-01(a)(5) of
         Regulation S-X, which would elicit both annual and interim periods
financial statement
         disclosures prescribed by new accounting principles and practice in
each quarterly report
         in the year of adoption.
3.       We note your accounting policy for the recognition of maintenance
revenue. Please
         describe to us the basis in GAAP for this policy.
        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 Tracie Mariner, Staff Accountant, at (202) 551-3744, or
Jenn Do, Staff
Accountant, at (202) 551- 3743, if you have questions regarding comments on the
financial
statements and related matters.



                                                               Sincerely,
FirstName LastNameScott Christopher
                                                        Division of Corporation
Finance
Comapany NameFortress Transportation & Infrastructure Investors LLC
                                                        Office of Manufacturing
and
September 21, 2018 Page 2                               Construction
FirstName LastName