September 24, 2018

Laurance Roberts
Chief Financial Officer
El Pollo Loco Holdings, Inc.
3535 Harbor Boulevard, Suite 100
Costa Mesa, California 92626

       Re: El Pollo Loco Holdings, Inc.
           Form 10-K for the Fiscal Year Ended December 27, 2017
           Filed March 9, 2018
           Form 10-Q for the Quarterly Period Ended June 27, 2018
           Filed August 3, 2018
           Form 8-K Furnished August 3, 2018
           File No. 001-36556

Dear Mr. Roberts:

       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 Fiscal Year Ended December 27, 2017

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Key Performance Indicators, page 35

1.    Refer to your paragraph discussion of Restaurant Contribution and
Restaurant
      Contribution Margin on page 36. As these key performance indicators are
also non-
      GAAP measures, your tabular reconciliation should begin with the most
directly
      comparable GAAP measure of operating income, rather than Company-operated
      restaurant revenue. Please revise accordingly. See Question 102.10 of the
Staff's
      Compliance & Disclosure Interpretations of NonGAAP Financial Measures,
updated
 Laurance Roberts
FirstName LastNameLaurance Roberts
El Pollo Loco Holdings, Inc.
Comapany 24, 2018 Pollo Loco Holdings, Inc.
September NameEl
September 24, 2018 Page 2
Page 2
FirstName LastName
         April 4, 2018 and Item 10(e)(1)(i)(A) of Regulation S-K. In addition,
please expand
         your narrative discussion to clearly indicate the nature of the costs
being excluded from
         restaurant contribution, that the measure is not indicative of overall
results for the
         Company, and that restaurant contribution margin does not accrue
directly to the benefit
         of shareholders because of corporate-level expenses excluded from the
measure. See Item
         10(e)(1)(i)(C) of Regulation S-K.

Note 15. Quarterly Results of Operations (Unaudited), page 82

2.       We note that your table of quarterly financial information includes
disclosure of restaurant
         contribution margin. As this is considered a non-GAAP financial
measure, please revise
         to remove its disclosure from your notes to the financial statements.
See Item
         10(e)(1)(ii)(C) of Regulation S-K.
Form 10-Q for the Quarter Ended June 27, 2018

Note 10. Revenue From Contracts With Customers, page 22

3.       We note your disclosure on page 15 that rental income for leases and
subleases to
         franchisees are outside of the scope of the revenue standard and are
within the scope of
         lease guidance.We also note from your disclosure in Note 10 that
Franchise revenue
         consists of franchise royalties, initial franchise fees, license fees
due from franchisees, IT
         support services, and rental income for leases and subleases to
franchisees. Please revise
         to disclose the amount of revenue recognized from contracts with
customers separately
         from other sources of revenue, such as revenue from leases. See
guidance in ASC 606-10-
         50-4(a).
Form 8-K Furnished August 3, 2018

Exhibit 99.1 Earnings Release, page 2

4.       We note that in the 2018 Outlook section, you disclose 2018 expected
pro forma diluted
         net income per share and a range for expected Adjusted EBITDA. Please
revise to
         include a reconciliation of these non-GAAP financial measures to the
projected GAAP
         measures, or alternatively include the disclosures required under Item
10(e)(1)(i)(B) of
         Regulation S-K if relying on the "unreasonable efforts" exception. See
Question 102.10
         of the SEC Staff's Compliance & Disclosure Interpretations on Non-GAAP
Financial
         Measures, updated April 4, 2018.
       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.
 Laurance Roberts
El Pollo Loco Holdings, Inc.
September 24, 2018
Page 3

      You may contact Beverly Singleton at (202) 551-3328 or Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNameLaurance Roberts                       Sincerely,
Comapany NameEl Pollo Loco Holdings, Inc.
                                                         Division of
Corporation Finance
September 24, 2018 Page 3                                Office of
Transportation and Leisure
FirstName LastName