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 August 6, 2025

Todd Telesz
Chief Financial Officer
Hallador Energy Co
1183 East Canvasback Drive
Terre Haute, Indiana
47802

 Re: Hallador Energy Co
 Form 10-K for the Fiscal Year ended December 31, 2024
 Filed March 17, 2025
 File No. 001-34743
Dear Todd Telesz:

 We have reviewed your filing and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Year ended December 31, 2024
Properties, page 39

1. We note that you include a comparison of proven and probable mineral
reserves for
 the Oaktown Mining Complex on page 49, which indicates reserves
decreased from
 60.7 million tons at December 31, 2023 to 34.5 million tons at December
31, 2024,
 although the disclosure does not include the required explanations.

 Please expand your comparison of mineral reserves to include the
information
 prescribed by Item 1304(e)(2) and (4) of Regulation S-K, i.e. specifying
the net
 difference between the two years as a percentage of the earlier amount,
and indicating
 the extent to which the change is attributable to depletion, production,
changes in the
 mining methods or model utilized for estimation, and changes in
commodity prices,
 operating costs, and acquisitions or disposals, as appropriate.
 August 6, 2025
Page 2

 Please also revise your disclosures on pages 47, 48 and 50, referencing
Exhibits 99.1
 and 99.2 for an updated technical report summary regarding your
estimates of mineral
 reserves prepared by the qualified person, and a March 7, 2025 letter
from the
 qualified person, as these appear to be inaccurate; we see that you
filed a report at
 Exhibit 96.1 although this does not appear to include the letter.

Financial Statements
Note 1 - Summary of Significant Accounting Policies
Long-term Contracts, page 74

2. We note your disclosures indicating the number of customers associated
with 89% of
 delivered energy revenue, 88% of capacity revenue, and 94% of
third-party coal sales,
 where revenues derived from such customers individually were 10% or more
of total
 revenues for the classification; and it appears that you have taken a
similar approach
 in formulating the significant customer disclosures on pages 23 and 51.

 Please expand your disclosures to indicate the amount of revenue for
each customer
 that accounts for 10 percent or more of the total and to specify the
segment in which
 the revenue is reported to comply with FASB ASC 280-10-50-42.

 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.

 Please contact Yong Kim at 202-551-3323 or Karl Hiller at 202-551-3686
if you have
questions regarding comments on the financial statements and related matters.
Please contact
John Coleman at 202-551-3610 if you have questions regarding the engineering
comment.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
cc: Sean Ewen
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