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January 4, 2022

VIA EDGAR TRANSMISSION

Office of Energy & Transportation

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: P.A.M. Transportation Services,
Inc.

    Form 10-K for the Fiscal Year Ended December 31,
2020

    Filed March 5, 2021

    File
No. 000-15057

Ladies and Gentlemen:

The following is the response of P.A.M. Transportation
Services, Inc. (“P.A.M.” or the “Company”) to the comment contained in the letter from the Office of Energy &
Transportation (the “Staff”) to Mr. Allen W. West, dated December 20, 2021. For convenient reference, this response letter
duplicates the text of the enumerated Staff comment, as well as the headings contained in the Staff’s letter.

Form 10-K for the Fiscal Year Ended December 31, 2020

Selected Financial Data, page 21

 1. We note your response to our prior comment indicates that you will provide clarifying disclosures regarding
your metrics in future filings. Please provide us with your proposed revised disclosures based on the metrics provided in the Form 10-K
for the fiscal year ended December 31, 2020.

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Response:

Below are the Company’s
proposed revised disclosures based on the metrics provided in the Form 10-K for the fiscal year ended December 31, 2020, as specifically
noted in the Staff’s initial comment dated November 30, 2021. Specifically, the Company proposes to supplement the Selected Financial
Data table and footnotes in the Form 10-K to include the additional operating data and footnote disclosures marked as follows:

    Year Ended December 31,

    Operating Data:
    2020 2019
    2018
    2017
    2016

    Operating revenues, before fuel surcharge, for
    truckload services
      337,529
      363,593
      356,569
      322,425
      338,323

    Operating revenues, before fuel surcharge, for brokerage and
    logistics services
      101,458
      75,918
      89,286
      51,098
      44,413

    Operating ratio (1)
      92.3%
      97.1%
      90.7%
      96.6%
      94.8%

    Average number of truckloads per week
      6,859
      8,405
      8,420
      7,134
      6,827

    Average miles per trip
      553
      499
      521
      635
      684

    Total miles traveled (in thousands)
      193,481
      213,048
      222,738
      229,392
      237,266

    Average trucks in fleet (2)
      2,003
      2,075
      1,901
      1,835
      1,891

    Average miles per truck
      96,532
      102,674
      117,169
      125,009
      125,471

    Average revenue, before fuel surcharge per truck per day (3)
    $ 863
    $ 834
    $ 923
    $ 805
    $ 797

    Average revenue, before fuel surcharge per loaded mile (4)
    $ 1.91
    $ 1.84
    $ 1.71
    $ 1.51
    $ 1.53

    Empty mile factor
      8.8%
      7.3%
      6.3%
      6.8%
      6.8%

    At end of period:

    Total company-owned/leased trucks (5)
      2,013
      2,130
      2,031
      1,721
      1,855

    Average age of company-owned trucks (in years)
      1.44
      1.46
      1.20
      1.49
      1.49

    Total company-owned/leased trailers (6)
      7,220
      7,081
      6,397
      5,795
      5,699

    Average age of company-owned trailers (in years)
      4.92
      4.18
      3.54
      3.38
      2.71

    Number of employees and independent contract drivers
      2,996
      3,242
      3,345
      2,969
      3,216

____________

 (1) Total operating expenses, net of fuel surcharge as a percentage
of operating revenues, before fuel surcharge.

 (2) Calculated as the average
                                            of the number of trucks in the fleet during each day within the period, including independent
                                            contractor trucks.

 (3) Consists of total operating
                                            revenues, before fuel surcharge, divided by average trucks in fleet, and further divided
                                            by 254 work days in each year, which excludes weekends, federal holidays and February 29
                                            in leap years.

 (4) Consists of total operating
                                            revenues, before fuel surcharge, for truckload services, divided by total miles traveled,
                                            net of empty miles.

 (5) Includes the following numbers of independent contractor trucks:
355 in 2020, 553 in 2019, 597 in 2018, 560 in 2017, and 578 in 2016.

 (6) Includes the following numbers of leased trailers: 0 in 2020,
56 in 2019, 43 in 2018, zero in 2017, and 232 in 2016.

If you have any questions or require further information,
please do not hesitate to contact me at

(479) 361-5409.

Sincerely,

/s/ Allen W. West

Allen W. West

Chief Financial Officer

 cc: Via E-mail

    Courtney C. Crouch, III, Esq.

    Mitchell, Williams, Selig, Gates & Woodyard,
P.L.L.C.

    Jason M. Butler, Partner

    Grant Thornton

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