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 July 18, 2025

Ron Bain
Chief Financial Officer
VAALCO Energy, Inc.
2500 CityWest Blvd., Suite 400
Houston, Texas 77042

 Re: VAALCO Energy, Inc.
 Form 10-K for the Fiscal Year ended December 31, 2024
 Filed March 17, 2025
 File No. 001-32167
Dear Ron Bain:

 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
Business
Reserve Information
Proved Undeveloped Reserves, page 18

1. We note the line item figure for extensions and discoveries shown in
your
 reconciliation of the changes in proved undeveloped reserves is a
negative value.
 However, the change due to extensions and discoveries should be a
positive value as it
 is intended to represent additions to proved reserves, consistent with
the description of
 extensions and discoveries in FASB ASC 932-235-50-5(d). This also
applies to the
 corresponding line item in the reconciliation of changes in proved
reserves for 2024
 under the section Estimated Quantities of Proved Reserves in the
Supplemental
 Information on Crude Oil, Natural Gas and NGLs Producing Activities.

 Please revise your reconciliation and explanation of changes as
appropriate; include
 the revisions that you propose along with your response.
 July 18, 2025
Page 2

2. Please refer to Rule 4-10(a)(31)(ii) of Regulation S-X and the answer to
Question
 131.04 of our Compliance and Disclosure Interpretations (C&DIs) of the
Oil and Gas
 Rules, regarding undrilled locations, and expand your disclosure to
clarify, if true, that
 all of the proved undeveloped reserves as of December 31, 2024 are part
of a
 development plan adopted by management indicating your undeveloped
reserves are
 scheduled to be drilled within five years of initial disclosure.

 However, if there are material volumes of proved undeveloped reserves
disclosed as
 of December 31, 2024 which will not be converted to proved developed
status within
 five years of initial disclosure as proved reserves, also explain the
reasons for the
 delay to comply with Item 1203(d) of Regulation S-K. Please ensure that
your
 circumstances would appropriately justify a time period that is longer
than five years,
 if applicable, considering the guidance in the answer to Question 131.03
of our
 Compliance and Disclosure Interpretations (C&DIs) regarding the Oil and
Gas Rules.

 You may view the C&DIs at the following website address:
https://www.sec.gov/

rules-r
egulations/staff-guidance/compliance-disclosure-interpretations/oil-gas-rules

Controls Over Reserve Estimates, page 18

3. We note you disclose material additions to your proved reserves for the
year ended
 December 31, 2024. Please expand your disclosure to provide a general
discussion of
 the technologies used to establish the appropriate level of certainty
for reserves
 estimates from material properties included in the total reserves
disclosed. Refer to the
 disclosure requirements in Item 1202(a)(6) of Regulation S-K.

Supplemental Information on Crude Oil, Natural Gas and NGLs Producing
Activities
(Unaudited)
Estimated Quantities of Proved Reserves, page F-49

4. Please expand your discussion of the changes that occurred to identify
the relevant
 acquisitions associated with the purchases of reserves in each year
where the change
 is significant to comply with FASB ASC 932-235-50-5(c).

5. We note the line item figure for extensions and discoveries shown in the
 reconciliation for the year ended December 31, 2024 appears inconsistent
with and
 less than the line item figure shown in the reconciliation of the
changes in proved
 undeveloped reserves presented on page 18. Please revise your
disclosures as
 necessary to address this apparent inconsistency.

Changes in Standardized Measure of Discounted Future Net Cash Flows, page F-54

6. If you will need to revise the estimated net quantities attributed to
extensions and
 discoveries in the reconciliation of the changes in total proved
reserves, you will also
 need to incorporate a corresponding revision to the changes in the
standardized
 measure of discounted future net cash flows for the year ended December
31, 2024.
 July 18, 2025
Page 3

 Please submit the revisions that you propose to address these concerns.

 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 John Hodgin at 202-551-3699 if you have questions
regarding the
engineering comments. Please contact Karl Hiller, Branch Chief, at 202-551-3686
with any
other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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