SecProbe.io

September 11, 2024
Philip Riley
Chief Financial Officer and Executive Vice President of Strategy
Riley Exploration Permian, Inc.
29 E. Reno Avenue, Suite 500
Oklahoma City, Oklahoma 73104
Re:Riley Exploration Permian, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2023
Filed March 6, 2024
File No. 001-15555
Dear Philip Riley:
            We have reviewed your filing and have the following comment(s).
            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.
Annual Report for the fiscal year ended December 31, 2023
Business and Properties
Oil, Natural Gas and NGL Reserves
Proved Undeveloped Reserves (PUDs), page 10
1.We note that the PUD conversion rates for the years ended December 31, 2022 and
December 31, 2023 were substantially below the 20% rate implied by the 5 year rule.
Describe for us the factors that impacted your conversion rates for each of those years.
As part of your response, provide us with a schedule that shows, for each of the years
ended December 2021, December 31, 2022 and December 31, 2023, the development
schedule underlying the disclosed proved undeveloped reserve volumes.  For each year
end, the schedule should show the locations and volumes to be developed, as well as the
related capital expenditures, by year for each year in your adopted five year development
plan.  Additionally, provide the actual PUD locations and volumes developed, and related
capital expenditures, for the years ended December 31, 2002 and December 31, 2023 and
year-to-date 2024.
Disclosure under this section regarding changes to your PUD volumes identifies various 2.

September 11, 2024
Page 2
factors without indicating the quantity attributable to each factor. Please expand the
disclosure of the changes in the net quantities of proved undeveloped reserves to include
an explanation of the material changes related to each line item shown in your
reconciliation. To the extent that two or more unrelated factors are combined to arrive at
the line item figure, your disclosure should separately identify and quantify each
individual factor that contributed to a material change so that the change in net reserves
between periods is fully explained.

The disclosure of revisions in the previous estimates of reserves should identify such
factors as changes caused by commodity prices, well performance, unsuccessful and/or
uneconomic proved undeveloped locations or the removal of proved undeveloped
locations due to changes in a previously adopted development plan. Refer to Item 1203(b)
of Regulation S-K.
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
(15) Supplemental Oil and Gas Information (Unaudited)
Oil, Natural Gas and NGL Quantities, page F-37
3.Your disclosure regarding changes in reserve quantities during the year ended December
31, 2023 indicates, in part, that you had downward revisions of 12.1 MMBoe which are
primarily attributable to the removal of PUDs due to changes in your development
schedule.  However, discussion of changes in your PUD volumes appearing on page 10 of
your filing indicates that downward revisions of your PUD volumes, due to several
different factors, were limited to 5.7 MMBoe.  Revise the disclosure related to revisions
in previous estimates to separately identify and quantify each factor, including offsetting
factors, such that the change to the line item is fully explained.  The revised disclosure
should indicate the extent to which changes were caused by economic factors, such as
costs and commodity prices, well performance, uneconomic proved undeveloped
locations, or the removal of proved undeveloped locations due to changes in a previously
adopted development plan. Refer to FASB ASC 932-235-50-5.
            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 Sandra Wall, Petroleum Engineer, at 202-551-4727 or Brad Skinner,
Office Chief, at 202-551-3489 if you have questions regarding the engineering comments.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation