SecProbe.io

December 20, 2018
Lawrence D. Martin
Chief Financial Officer
Hallador Energy Company
1660 Lincoln Street, Suite 2700
Denver, CO 80264-2701
Re:Hallador Energy Company
Form 10-K for Fiscal Year Ended December 31, 2017
Filed March 13, 2018
Form 8-K filed November 7, 2018
File No. 001-34743
Dear Mr. Martin:
            We have reviewed your filings 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 Fiscal Year Ended December 31, 2017
Notes to Consolidated Financial Statements
(1) Summary of Significant Accounting Policies, page 48
1.Please tell us how you have applied the guidance in FASB ASC 280-10 “Segment
Reporting” in regards to the identification of your Chief Operating Decision Maker
(“CODM”), the identification of your operating segments, and presentation of your
reportable segments.  Please include an analysis of the various factors you considered in
identifying your operating segments pursuant to ASC 280-10-50-1 including the nature of
the information provided to the CODM, the budgeting process, compensation, and the
management and organizational structure between the CODM and your coal mining
operations and any other factors that may be applicable.

 FirstName LastNameLawrence D. Martin
 Comapany NameHallador Energy Company
 December 20, 2018 Page 2
 FirstName LastName
Lawrence D. Martin
Hallador Energy Company
December 20, 2018
Page 2
Inventories, page 48
2.You disclose that coal inventory costs include labor, supplies, equipment costs (including
depreciation thereto) and overhead.  Please expand your disclosure to address whether
depreciation, depletion and/or amortization of land and mineral rights, mine development
costs and buildings are included in inventory costs.
Form 8-K Filed November 7, 2018
Exhibit 99.1
3.We note you present the non-GAAP measures Adjusted EBITDA and Adjusted Free Cash
Flow in your exhibit furnished under Item 2.02 of this Form 8-K.  Please include a
reconciliation of these non-GAAP measures to the most directly comparable financial
measure or measures calculated and presented in accordance with GAAP.  Refer to Item
10(e)(1)(i)(B) of Regulation S-K.
            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 James Giugliano at (202) 551-3319, or Angela Lumley at (202) 551-
3398, with any questions.
Sincerely,
Division of Corporation Finance
Office of Beverages, Apparel and
Mining