SecProbe.io

April 2 5, 2013

Via E -mail
Mr. W. Anderson Bishop
Chief Financial Officer
Hallador Energy Company
1660 Lincoln Street, Suite 2700
Denver, Colorado  80264 -2701

Re: Hallador Energy Company
 Form 10-K for Fiscal Year Ended December 31, 2012
Filed  March 7, 2013
File: No. 001-34743

Dear Mr. Bishop :

We have reviewed your filing an d 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advising us when you will provide the requested
response.   If you do not believe our comments apply to your facts and circumstance s or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these  comments, we may have  additional comments.

Active Reserve (assigned) - Carlisle Mine (underground), page 2

1. Proven and probable reserves are disclosed for your Carlisle, Ace -in–the–hole,
(Allerton?), Bulldog, and Russellville properties.  Please forward  to our engineer as
supplemental information and not as part of your filing, your information that establishes
the legal, technical, and economic feasibility of your materials designated as res erves, as
required by Section C of Industry Guide 7 pursuant to  Rule 12b -4 of the Exchange Act.
The information requested includes, but is not limited to:

 Property and geologic maps

 Description of your sampling and assaying procedures

Mr. W. Anderson Bishop
Hallador Energy Company
 April 2 5, 2013
 Page 2

  Drill -hole maps showing drill intercepts

 Representative geologic cross -sections  and drill logs

 Description and examples of your cut -off calculation procedures

 Cutoff grades used for each category of your reserves and resources

 Justifications for the drill hole spacing used to classify and segregate proven and
probable reserves

 A detailed description of your procedures for estimating reserves

 Copies of any pertinent engineering or geological reports, and executive summaries
of  feasibility studies or mine plans which including the cash flow analyses

 A detailed permitting and gove rnment approval schedule for the project, particularly
identifying the primary environmental or construction approval(s) and your current
location on that schedule.

To minimize the transfer of paper, please provide the requested information on a CD,
forma tted as Adobe PDF files and provide the name and phone number for a technical
person our engineer may call, if he has technical questions about your reserves.

In the event your company desires the return of this supplemental material, please make a
writte n request with the letter of transmittal and include a pre -paid, pre -addressed
shipping label to facilitate the return of the supplemental information.  Please note that
you may request the return of this information pursuant to the provisions of Rule 12b -4 of
the Exchange Act.

If there are any questions concerning the above request, please  phone Mr. George K.
Schuler, Mining Engineer at (202) 551 -3718.

2. Please disclose if you have had qualified title companies confirm your property right
assertions for all your properties.  Discuss what type of title review you have for the
majority of your reserves.

Reserve Table  - Controlled Tons (in Millions) , page 3

3. Please make the following changes to your reported reserve table and disclose your
proven and probab le reserves separately as defined in Industry Guide 7 for each mine.

 Indicate tonnages that are “assigned” to an existing facility and those that have not
been “assigned.”

Mr. W. Anderson Bishop
Hallador Energy Company
 April 2 5, 2013
 Page 3

 Disclose if the coal is steam or metallurgical, if it is leased or owned, and what  is the
Btu per pound and the percentage sulfur content.  Do not report Btu content as “dry,”
but include natural moisture in the calculation.  Do not report reserves that are not
controlled by your company.

 If coal is reported as tons in the ground, disc lose in another column the average
mining and wash plant recoveries in percent; and indicate whether these losses have
or have not been reflected in the total recoverable reserves.

 In either case, with a footnote clearly disclose if the reserves reported are “in the
ground” or “recoverable.”

 Provide totals to the reserve table where appropriate.

 Disclose your percentage of compliance and non -compliance coal.

Mining Permits and Approval s, page 5

4. We note you are subject to permitting requirements administered by the local, state, and
Federal governments.  Please revise your filing and provide a short summary of the
permits and/or operational plans required to perform exploration and/or mining activ ities
on your properties and discuss in greater detail the government and environmental
regulations to which you are subject .  Please fully discuss the permitting, bonding, and
reclamation requirements for each phase of your exploration work including the specific
permits and associated fees.  In your discussion, include the specific permits that your
company has obtained or will obtain to perform each phase of you exploration program.
Describe the effect of existing or probable governmental regulations on  your business.
See Item 101(h) (4) (viii), (ix) and (xi) of Regulation S -K.

Additional Disclosures for the Carlisle Mine, Page 8

5. Please insert a small -scale map showing the location and access to your properties into
your filing.  See Item 102 (3) (B) o f Regulation S -K.  Briefly describe the road, barge
and/or railroad access to each of your properties in the text.  Please note that SEC’s
EDGAR program now accepts digital maps.  So please include these in any future
amendments that are uploaded to EDGAR.   It is relatively easy to include automatic links
at the appropriate locations within the document to GIF or JPEG files, which will allow
the figures and/or diagrams to appear in the right location when the document is viewed
on the Internet.  For more in formation, please consult the EDGAR manual, and if you
need addition assistance, please call Filer Support at 202 -942-8900.  Otherwise provide
the map to the engineering staff for our review.

Mr. W. Anderson Bishop
Hallador Energy Company
 April 2 5, 2013
 Page 4

 6. For each of your  mines  or properties , provide the disclosures r equired by Industry Guide
7 (b).  In particular, provide a brief discussion of:

 The coal beds of interest, including minable coal thickness.

 The description and capacities of the mine, general mining equipment used and other
infrastructure facilities that is present .

 A list of your coal processing and/or handling facilities.

 Please discuss your access to an adequate water and power supply.

 The road, barge and/or railroad access to each of your properties.

 The present condition of the mine.

 Material events of interest concerning the mine, adverse or otherwise within the last
three years.

 Any mine expansions, contractions or decommissioning within the last three years.

 Any planned expansions or reductions in mining.

 Any joint ownership.

 Any use of mining contractors.

7. Detailed sampling provides  the basis for the quality estimate or grade of your mineral
reserves and deliveries to customers.  Please provide a brief description of your sample
collection, sample preparation, and the analytical procedur es used to develop your
analytical results.  In addition, please disclose any Quality Assurance/Quality Control
(QA/QC) protocols you have developed.  These procedures would serve to inform
potential investors regarding your sample collection and preparati on, analytical controls,
sample custody, precision and accuracy procedures and protocols.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of th e disclosures they have made.

 In responding to our comments, please provide  a written statement from the company
acknowledging that:

Mr. W. Anderson Bishop
Hallador Energy Company
 April 2 5, 2013
 Page 5

 the company is responsible for the adequacy and accuracy of the disclosure in the filing;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the fe deral securities laws of the United States.

You may contact George Schuler, Mining Engineer, at (202) 551 -3718 with questions
about these comments.  Please contact me at (202) 551 -3795 with any other questions.

Sincerely,

       /s/ John Reynolds

John Reynolds
Assistant Direc tor