October 24, 2019

David C. Burney
Chief Financial Officer
Astronics Corporation
130 Commerce Way
West Aurora, NY 14052

       Re: Astronics Corporation
           Form 10-K for the Year Ended December 31, 2018
           Form 8-K furnished on August 5, 2019
           File No. 000-07087

Dear Mr. Burney:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment. In some of our comments, 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 8-K funished on August 5, 2019

Non-GAAP Performance Measures

1.    We note your non-GAAP measures for adjusted consolidated sales, adjusted
income from
      operations and adjusted net income which include adjustments to eliminate
all sales and
      associated direct costs of your semiconductor business in the reported
periods, although
      the divestiture of your semiconductor test business was not accounted for
as discontinued
      operations pursuant to ASC 205-20. As such, your non-GAAP measures appear
to
      substitute individually tailored recognition and measurement methods for
those of
      GAAP, which is inconsistent with the guidance provided in Question 100.04
of the Non-
      GAAP Compliance and Disclosure Interpretations. In future filings, please
revise your
      non-GAAP presentations to comply with this guidance.
 David C. Burney
Astronics Corporation
October 24, 2019
Page 2

       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.

       You may contact Melissa Gilmore at (202) 551-3777 or Martin James at
(202) 551-3671
with any questions.



FirstName LastNameDavid C. Burney                         Sincerely,
Comapany NameAstronics Corporation
                                                          Division of
Corporation Finance
October 24, 2019 Page 2                                   Office of
Manufacturing
FirstName LastName