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                                                           May 13, 2019

Richard B. Cribbs
Chief Financial Officer
Covenant Transportation Group, Inc.
400 Birmingham Hwy.
Chattanooga, Tennessee 37419

       Re: Covenant Transportation Group, Inc.
           Form 10-K for the Year Ended December 31, 2018
           Form 8-K furnished March 19, 2019
           Form 8-K furnished April 25, 2019
           File No. 000-24960

Dear Mr. Cribbs:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 the Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Executive Overview, page 37

1.    We note your presentation of "aggregate lease adjusted indebtedness." The
measure
      appears to represent a non-GAAP measure defined by and subject to the
provisions of
      Regulation G and Item 10(e) of Regulation S-K. In this regard, please
revise to include
      the following disclosures:
        Clearly label the measure as non-GAAP and present the most directly
comparable
          GAAP measure with equal or greater prominence per Item 10(e)(i)(A) of
Regulation
          S-K;
        Provide a reconciliation to the most directly comparable GAAP measure
according to
          Item 10(e)(i)(B) of Regulation S-K; and
        Disclose the usefulness to investors and management's use of the
measure pursuant to
 Richard B. Cribbs
FirstNameTransportation Group, Cribbs
Covenant LastNameRichard B. Inc.
Comapany NameCovenant Transportation Group, Inc.
May 13, 2019
May 13, 2019 Page 2
Page 2
FirstName LastName
             Item 10(e)(1)(i)(C) and (D) of Regulation S-K.
Liquidity and Capital Resources, page 47

2.       We note your disclosure in the second paragraph that you had $3.9
million of borrowings
         outstanding at December 31, 2018. However, we further note that your
indebtedness
         totaled approximately $236 million at December 31, 2018 per note 6 to
your financial
         statements. To balance the disclosure, please revise your liquidity
discussion on page 47
         to present not only your borrowings under the Credit Facility, but
your revenue equipment
         notes, real estate notes, notes payable, and capital lease obligations
since both impact your
         liquidity.
3.       Please revise your MD&A discussion of cash flows from operating,
investing and
         financing activities to cover the three years presented in your
financial statements. Refer
         to Item 303(a) of Regulation S-K.
Financial Statements
Notes to Consolidated Financial Statements
1. Summary of Significant Accounting Policies
Revenue Recognition, page 73

4.       We note your disclosure that revenue, drivers' wages and other direct
operating expenses
         generated by your Truckload reportable segment are recognized
proportionally as the
         transportation service is performed based on the percentage of miles
completed as of the
         period end. Please explain to us why you believe it is appropriate to
recognize expenses
         such as drivers' wages and other direct operating expenses
proportionally rather than as
         incurred.
5.       We also note that revenue includes transportation revenue, fuel
surcharges, loading and
         unloading activities, equipment detention, and other accessorial
services. Please explain
         to us the nature of the performance obligations in your contracts. If
these additional
         activities represent separate performance obligations, please tell us
and revise to disclose
         how you allocate transaction price to each separate performance
obligation. Please refer
         to ASC 606-10-50-17 and 20. Also, please revise to disclose the nature
of significant
         payment terms. See ASC 606-10-50-12.
4. Property and Equipment, page 81

6.       Please provide a rollforward of your property and equipment balance
from December 31,
         2017 to December 31, 2018. In this regard, we note from your statement
of cash flows
         and Note 15 that you acquired property and equipment in the Landair
Holdings acquisition
         and through your normal capital purchases, as well as disposed of a
significant amount of
         property and equipment, yet your overall balance from 2017 to 2018 has
decreased. It
         would be helpful to provide detail of the activity in the gross
amounts and accumulated
         depreciation during the year. Please revise accordingly.
 Richard B. Cribbs
Covenant Transportation Group, Inc.
May 13, 2019
Page 3


15. Acquisition of Landair Holdings, Inc., page 89

7.       We refer to your statement on page 90 that the pro forma financial
information includes
         additional interest expense as a result of financing obtained for the
Landair acquisition.
         Given that your bank borrowings actually decreased from 2017 to 2018,
please provide
         further details on the nature of the borrowings that financed the
acquisition.
Form 8-K furnished March 19, 2019

Exhibit 99.1, page 1

8.       We refer to your statement by your CEO that states the expected
adjusted net income for
         the first quarter of 2019. As adjusted net income is a non-GAAP
measure, please also
         disclose GAAP net income and include a reconciliation to the most
directly comparable
         GAAP measure in accordance with Regulation G. In addition, as Item
10(b) of
         Regulation S-K states that the typical financial items for projections
of importance to
         investors are revenues, net income (loss), and earnings (loss) per
share, please balance
         your discussion of expected adjusted net income to include some or all
of these GAAP
         measures.
Form 8-K furnished April 25, 2019

Exhibit 99.1, page 1

9.       We note your presentation of non-GAAP measures and the corresponding
reconciliations
         to the most directly comparable GAAP measures on the last page of your
exhibit. Please
         revise to also include a discussion of why the measures are useful to
investors as well as
         the purposes for which management uses the non-GAAP measures in
accordance with
         Item 10(e)(1)(i)(C) and (D) of Regulation S-K. See also Instruction 2
to Item 2.02 of
         Form 8-K.
       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 Heather Clark at 202-551-3624 or Claire Erlanger at
202-551-3301 with
any questions.



FirstName LastNameRichard B. Cribbs                            Sincerely,
Comapany NameCovenant Transportation Group, Inc.
May 13, 2019 Page 3                                            Division of
Corporation Finance
FirstName LastName                                             Office of
Transportation and Leisure
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