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January 20, 2016

Securities and Exchange Commission

Judiciary Plaza

450 Fifth Street, NW

Washington, DC 20549

Attention: H. Roger Schwall

    Re:
    EnerJex Resources, Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2014

    Filed March 31, 2015

    Definitive Proxy Statement on Schedule 14A

    Filed April 3, 2015

    File No. 1-36492

Dear Mr. Schwall

In response to your letter
dated December 21, 2015, set forth below are your comments concerning the EnerJex Resources, Inc.'s Form 10-K and Definitive Proxy
Statement referred to above, and our responses. Your comments are in italics and are followed by our response.

Form 10-K for the Fiscal Year Ended December 31, 2014

Business and Properties, page 4

Reserves, page 11

 1. Please expand the tabular presentations on pages 11, 34 and F-19 to separately disclose material reserves by product type
of crude oil including condensate, natural gas liquids and natural gas. You may refer to Item 1202(a)(1) of Regulation S-K and
FASB ASC 932-235-55-2 for illustrations of the presentation requirements of Item 1202(a)(4) of Regulation S-K and FASB ASC 932-235-50-4
and 50-5.

EnerJex response:

We plan to include the following information
in our Form 10-K for the fiscal year ended December 31, 2014, under Business and Properties – Reserves, and to include similar
information in other future filings:

    4040 Broadway, Suite 508 | San Antonio, TX 78209 | 210-451-5545 (P) | 210-463-9297 (F)

Summary of Proved Oil and Gas Reserves

as of December 31, 2014

    Gross
    Net
    PV10
(before
    tax)

    Crude Oil
    Natural Gas Liquids
    Natural Gas
    Oil Equivalents
    Crude Oil
    Natural Gas Liquids
    Natural Gas
    Oil Equivalents

    Proved Reserves Category
    BBL
    BBL
    MCF
    BOE
    BBL
    BBL
    MCF
    BOE

    Proved, Developed
      3,067,808
      114,021
      8,387,078
      4,579,675
      2,271,183
      90,851
      4,117,356
      3,048,261
      51,942,200

    Proved, Undeveloped
      931,287
      -
      4,940,000
      1,754,621
      675,266
      -
      4,059,920
      1,351,919
      12,376,500

    Total Proved
      3,999,096
      114,021
      13,327,079
      6,334,296
      2,946,449
      90,851
      8,177,276
      4,400,180
      64,318,700

 2. Based on the disclosure provided on page F-19, there appears to be a material change in proved undeveloped reserves compared
to the disclosure of such reserves as of December 31, 2013. Under Item 1203(b) of Regulation S-K you are required to disclose material
changes in proved undeveloped reserves that occurred during the year, including proved undeveloped reserves that were converted
to developed reserves. Please expand your disclosure to provide both a tabulation and narrative explanation for the net changes
in reserve quantities relating to revisions, extensions/discoveries, acquisition/divestiture, improved recovery and the amounts
converted during the year from proved undeveloped to proved developed, including sufficient details to reconcile and understand
the overall change in net reserves.

EnerJex response:

We respectfully submit that at the time
of preparation and filing of our Annual Report, we considered the referenced regulations. The downward revisions in previous reserve
estimates is primarily related in revised forecasted declines rates in the Cherokee Project. Our third party engineering firm,
MHA Petroleum Consultants revised their decline curve forecast methodology in response to actual 2014 production performance data
that fell short of forecasts using the original methodology. These revisions resulted in a decrease in the estimated proved developed
reserves of approximately 600,000 BOE and proved undeveloped reserves of approximately 600,000 BOE. We sold the Cherokee Project
assets in the second quarter of 2015.

 3. Please expand your disclosure to include the information required under Item 1203(c) of Regulation S-K, regarding “…investments
and progress made during the year to convert proved undeveloped reserves to proved developed reserves, including, but not limited
to, capital expenditures.” This should include a discussion of the progress you have made during the year to convert your
proved undeveloped reserves to developed and quantify the capital expenditures incurred in converting your proved undeveloped reserves
to developed for this period of time.

EnerJex response:

We plan to include the following information
in our Form 10-K for the fiscal year ended December 31, 2014, under Business and Properties – Reserves, and to include similar
information in other future filings:

    4040 Broadway, Suite 508 | San Antonio, TX 78209 | 210-451-5545 (P) | 210-463-9297 (F)

In 2014 of the $7.1 million of capital invested
on oil and gas properties, approximately $6.4mm was spent developing oil and gas assets the remaining amount was spent acquiring
leasehold positions. Approximately $2.0 million was spent drilling and completing proved undeveloped location in the Company’s
Kansas properties with $1.4 million allocated to its Mississippian project and $.6 million allocated to its Cherokee project. In
Colorado approximately $1.0mm was invested in an oil trunk line in the Adena field and a gas tap and pipeline in the Amherst field.
Approximately $3.4mm was invested recompleting and reactivating well in the Adena field. The proved undeveloped investment rate
was dramatically decreased in the fourth quarter in response to falling commodity prices. The Company’s reserve report estimates
$13.5 million of remaining future development costs. The Company will have $3.1 million of cash on hand and estimates approximately
$3.0 million of unrealized hedge gains at year end. Given that the Company expects to have approximately fifty percent of cash
and liquid assets on hand to meet future estimated development costs, we believe that the readers of our financial statement are
best served by an expanded disclosure in the 2015 Annual Report on Form 10-K and all subsequent interim 2016 interim reporting
that specifically addresses: (1) our liquidity position, (2) our rationale as to why we choose not to deploy capital until there
has been a recovery in commodity prices, and (3) a full discussion of any deterioration to our liquidity position should that occur
in 2016 and the impact on our ability to convert proved undeveloped reserves into proved producing reserves in compliance with
item 1203 (c) of Regulation S-K.

 4. We note you disclose that proved undeveloped reserves at December 31, 2014 represent approximately 31% of total proved reserves.
Please expand your disclosure to explain your development plans sufficiently to understand how you have complied with the timeframe
stipulated for development within Rule 4-10(a)(31)(ii) of Regulation S-X, and how you have formulated a reasonable expectation
that any financing necessary to proceed with development will be available, as required by Rule 4-10(a)(26) of Regulation S-X,
prior to reporting these reserves. You should also disclose the information required by Item 1203(d) of Regulation S-K, regarding
the extent to which any of your proved undeveloped reserves will not be developed within five years of your initial disclosure
of these reserves.

If you expect that any of your proved undeveloped
reserves will take more than five years to develop since initial disclosure, please refer to the answer to question 131.03 in our
Compliance and Disclosure Interpretations (C&DIs), and describe for us the specific circumstances that you believe justify
an extended period of time. You may find the C&DIs on our website at http://www.sec.gov/divisions/corpfin/guidance/oilandgas-interp.htm.

EnerJex response:

When we file
our 2015 Annual Report on Form10-K, we will report over $3.1 million of cash and approximately $3.0 million of unrealized hedge
gains at December 31, 2015. We also believe working capital at year end will be positive and the current ratio will be greater
than 1:1. Therefore at year-end the Company will have half of the funds on hand necessary for future development costs estimated
in 2014 to be $13.5 million. While oil and gas prices are volatile and unpredictable, we believe in the next four years prices
will increase sufficiently to warrant the prudent deployment of capital to finish these development plans. Further, if this doesn’t
occur, we have the ability to enter into joint ventures (as we have done with other oil and gas assets) with these assets to complete
the conversion of these undeveloped locations. We believe our balance sheet provides us the wherewithal to develop these reserves
in the next four years. Should there be a protracted delay in commodity prices recovery lasting four years we would implement a
joint venture to complete the development of these reserves.

    4040 Broadway, Suite 508 | San Antonio, TX 78209 | 210-451-5545 (P) | 210-463-9297 (F)

We respectfully submit that instead of expanding
our prior disclosures that we could better serve the readers of our Annual Report and financial statements with an expanded discussion
of future development plans for the next four years in the Company’s annual and quarterly reports that specifically address:
(1) liquidity, (2) our position and rationale as to our decision to deploy or not deploy capital at that time and (3) a full discussion
of any deterioration to our liquidity should that occur and how this would impact our ability to convert proved undeveloped reserves
into proved producing reserves within the four year time frame.

 5. We note the disclosures on pages 22, 34 and F-19 indicate the estimates of reserves and future net cash flows attributable
to those reserves at December 31, 2014 were prepared by MHA Petroleum Consultants LLC, an independent petroleum consultant. Please
obtain and file a report from that firm, including all of the information specified in Item 1202(a)(8) of Regulation S-K.

EnerJex response:

We plan to include as an exhibit to our
Form 10-K for the fiscal year ended December 31, 2014 the letter from MHA Petroleum Consultants LLC attached hereto as Exhibit
A.

Management’s Discussion and Analysis of Financial Condition
and Results of Operations, page 33

 6. We note your disclosures among Risk Factors on pages 20 and 21 stating “Any substantial decline in the price of oil
and natural gas will likely have a material adverse effect on our planned operations and financial condition” and “A
substantial or extended decline in oil and gas prices would materially and adversely affect our future business enough to potentially
force us to cease our business operations.”

The disclosures in your third quarter report indicate
that the decline in commodity prices has led to substantial curtailment of capital expenditures, impairment of your oil and gas
properties of $37.5 million (58% of the property account at the beginning of the year), and the sale of producing assets to fund
cash obligations.

However, we do not see any disclosure in the MD&A
of your periodic filings explaining how known trends, demands, commitments, events and uncertainties are reasonably likely to affect
your liquidity, capital resources and results of operations, or are reasonably likely to cause your reported financial information
not to be necessarily indicative of your future operations or future financial condition.

Please comply with Item 303(a) and (b) of Regulation
S-K. You may find the guidance in Instructions 2, 3, 4 and 5 helpful in formulating your disclosures and quantifying the reasonably
likely effects of known trends, demands, commitments, events and uncertainties on your reserves, development plans and accounting.

You may also refer to the guidance in FRC §§
501.12.a, 501.12.b.3, and 501.14 (Sections III.A, III.B.3, and V of SEC Release Nos. 33-8350; 34-48960; FR-72), as it relates to
disclosures in an introductory section or overview, the effects of material trends and uncertainties, and critical accounting estimates.

EnerJex response:

We respectfully submit that
at the time of preparation and filing of our Annual Report, we considered the referenced regulations and guidance and determined
that we did not have a reasonable basis to quantify known trends, demands, commitments, events and uncertainties that are reasonably
likely to affect our liquidity, capital resources and results of operations, or that are reasonably likely to cause our reported
financial information not to be necessarily indicative of our future operations or future financial condition.

    4040 Broadway, Suite 508 | San Antonio, TX 78209 | 210-451-5545 (P) | 210-463-9297 (F)

At the time the referenced
risk factors were prepared and disclosed in our 2014 Annual Report, pricing determined pursuant to SEC guidelines ranged from $53.27
to $50.09. We believe the risk factors are true in the long term but due to the unpredictability of commodity prices could just
as likely ameliorate over the short term. We note that the cited MD&A regulations and guidance as to reasonably likely impacts
of known trends and uncertainties do not mandate quantifying estimates if not reasonably available. We further submit that a reasonable
basis would be required for determining and disclosing such forward–looking quantitative information. We interpreted the
disclosure requirements as requiring a basis that results in information that would be reasonably meaningful to investors, which
would not include arbitrary single point estimates or ranges of outcomes that would be so broad as to be more confusing than informative.

Therefore we believed it
prudent to wait for a trend to develop given our confidence in our strong balance sheet to outlast the market declines in crude
oil prices.

On March 31, 2015 the Company
reported almost $1 million in cash, $4.7 million of unrealized hedge gains and working capital of $3.3 million and a working capital
ratio of 1.8:1.

By May 15, 2015 the Company
liquidity and capital resources improved as $2.9 million of cash, $4.6 million of unrealized hedge gains and working capital of
$6.3 million and a working capital ratio of 2.8:1 was reported. Additionally, first of month prices improved ranging from $59.15
to $60.20.

By mid-year our liquidity
and capital resources decreased slightly as on August 14, 2015 we reported $1.9 million of cash, $2.6 million of unrealized hedge
gains and working capital of $4.1 million and a working capital ratio of 2.1:1 in our quarterly report on Form 10-Q for the second
quarter of 2015, and first of month pricing ranged between $47.12 and 45.41. Although liquidity had trended down it still reflected
a stable financial condition for the Company.

At the end of our third
quarter in 2015 we saw an improvement in our liquidity and capital resources reporting $3.0 million of cash, $3.1 million of unrealized
hedge gains and working capital of $5.6 million and a working capital ratio of 3.1:1 in our quarterly report on Form 10-Q for the
 third quarter of 2015.

On page 13 of each of our
first, second and third quarter interim reports we discuss potential negative impacts to future results of operations, and on page
17 of our third quarter interim report we expanded on this theme.

Throughout all of 2015 we
maintained or improved our working capital and improved our liquidity from yearend 2014 to year end 2015.

We respectfully submit that
our quarterly reporting regarding liquidity and capital resources adequately disclosed an improving situation while acknowledging
risk did not unduly emphasize the negative potentially misleading readers of the financial statements. Further, in light of the
passage of a significant amount of time since the preparation and filing of our 2014 Annual Report, we believe that the actual
outcomes in the first, second and third quarters of 2015 supported our concern that providing such quantifying estimates in the
Annual Report based