Mailstop 3233
                                                              August 15, 2018


   Via E-mail
   Mr. Paul Seavey
   Chief Financial Officer
   Equity Lifestyle Properties, Inc.
   Two North Riverside Plaza, Suite 800
   Chicago, IL 60606


          Re:    Equity Lifestyle Properties, Inc.
                 Form 10-K for the fiscal year ended December 31, 2017
                 Filed February 28, 2018
                 File No. 001-11718
                 Form 8-K
                 Filed May 15, 2018
                 File No. 001-11718


   Dear Mr. Seavey:

          We have limited our review of your filings 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.
 Mr. Paul Seavey
Equity Lifestyle Properties, Inc.
August 15, 2018
Page 2

Form 10-K for the fiscal year ended December 31, 2017

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations

Contractual Obligations, page 49

1.      Based on footnote (2), it appears interest expense disclosed only
relates to secured debt.
        To the extent material, please revise your disclosures in future
periodic reports to also
        discuss the cash requirements for interest related to unsecured debt.
Reference is made to
        footnote 46 of SEC Interpretive Release 33-8350 "Interpretation:
Commission Guidance
        Regarding Management's Discussion and Analysis of Financial Condition
and Results of
        Operations."

Form 8-K filed May 15, 2018

Exhibit 99.1 Investor Presentation

2.      We note your discussion of Free Cash Flow on page 11. Please revise
future
        presentations of free cash flow to include a presentation of the most
directly comparable
        GAAP financial measure and a quantitative reconciliation from such GAAP
financial
        measure to Free Cash Flow pursuant to Item 100(a)(1) and (2) of
Regulation G.


        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 Jeffrey Lewis, Staff Accountant, at (202) 551-6216 or
the undersigned
at (202) 551-3468 with any questions.


                                                            Sincerely,

                                                            /s/ Wilson K. Lee

                                                            Wilson K. Lee
                                                            Senior Staff
Accountant
                                                            Office of Real
Estate and
                                                            Commodities