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CORRESP
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November 1, 2024

Messrs. John Coleman and Craig Arakawa

Division of Corporation Finance

Office of Energy & Transportation

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:
    Arch Resources, Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2023

    Filed February 15, 2024

    File No. 001-13105

Dear Messrs. Coleman and Arakawa:

We are providing this letter in response to the
comments of the staff of the Securities and Exchange Commission (the “Staff”) contained in your letter dated October 25, 2024,
regarding the Annual Report on Form 10-K filed by Arch Resources, Inc. (the “Company”) for the Company’s fiscal year
ended December 31, 2023 (the “2023 10-K”). References to the “Company,” “Arch Resources,” “we,”
 “us” and “our” in this letter refer to Arch Resources Inc.

For your convenience, we have restated below
in bold each comment from the Letter and supplied our responses immediately thereafter. In response to each comment below, we have
proposed to alter our future disclosures to address the Staff’s comment. The Company respectfully submits that its prior
disclosure is accurate and complete in all material respects with respect to these matters. Capitalized terms not otherwise defined
in this letter have the meanings given to them in the 2023 10-K.

Form 10-K for the Fiscal Year Ended December 31, 2023

Item 2. Properties., Page 64

 1. We note that you have disclosed measured and indicated resources of 12.9 million tons for your Leer South property, however your
technical report for Leer South, filed as Exhibit 96.2, indicates that there are no mineral resources on the property, exclusive of reserves.
Please advise.

Response:

We respectfully acknowledge the Staff’s comment. The disclosed
resources associated with Leer South are controlled minerals that are located in the Clarion coal seam. These resources were initially
included in the Leer South technical study that was included as Exhibit 96.2 to our Annual Report on Form 10-K for the fiscal year ended
December 31, 2021, filed with the Commission on February 16, 2022 (the “2021 Filing”). These resources remain unchanged from
the 2021 Filing. In contrast, the technical report for Leer South, filed as Exhibit 96.2 to the 2023 10-K, only included coal in the Lower
Kittanning seam, as our current plans no longer include mining the Clarion coal seam. Although not included in our current plans, we retain
the ability to mine the Clarion coal seam in the future. We will revise our future filings to include these tons in a new category of mineral resources titled “Other NAPP (the Northern
Appalachian Basin).”

 2. Please address the following with respect to your S-K 1300 mineral property disclosure:

 o Include the commodity price for each resource, including nonmaterial properties, with your summary resource table and your summary
reserve table as required by Item 1303(b)(3) of Regulation S-K; and

 o Include the commodity price, cut-off grade, and process recovery factor with your individual property reserve tables as required
by Item 1304(d)(1) of Regulation SK. To the extent you do not use a traditional cut-off grade include a brief description of the parameters
and assumptions that distinguishes material deemed to have no economic value from material deemed to have economic value, for example
minimum quality specifications or other.

Response:

We respectfully acknowledge the Staff’s comment and plan to revise
the summary resource and reserve tables in future Annual Reports on Form 10-K to disclose projected realized coal price and recovery factors
for reserves. The tables below reflect examples of our proposed modified summary resource and reserve tables:

The following table shows our
estimates of Mineral Resources as of December 31, 2023, prepared in accordance with Subpart 1300 of Regulation S-K.

Total Mineral Resources

(Tons in millions)

    Representative
    In-Place Mineral Resources (million tons)
    Measured +

      Realized
                                            Coal

    Product / Region / Mine
    Coal Quality
    Measured(9)
    Indicated(9)
     Indicated(9)
    Inferred(9)
       Price(10)

    Metallurgical Coal

       Central Appalachia

         Mountain Laurel
    2
    2.5
    17.4
    19.9
    22.5
    $ 153

         VA, Royalty
    1
    16.3
    —
    16.3
    —
      —

       Total Central Appalachia

    18.8
    17.4
    36.2

      Northern Appalachia

          Leer
    2
    2.6
    12.6
    15.2
    4.9
    $ 161

          Leer South
    2
    8.9
    4.0
    12.9
    —
      150

          Other Northern Appalachia
    2
    77.5
    105.0
    182.6
    0.9
      157

       Total Northern Appalachia

    89.0
    121.6
    210.7

    Total Metallurgical Coal

    107.8
    139.0
    246.9

    Thermal Coal

      Colorado

        West Elk Mine
    3
    51.2
    10.7
    61.9
    —
    $ 65

      Illinois Basin

         Macoupin County, IL
    4
    —
    170.6
    170.6
    —
      42

         Other Illinois Basin
    5
    21.4
    106.0
    127.4
    56.2
      42

      Total Illinois Basin

    21.4
    276.6
    298.0
    56.2

      Wyoming

         Black Thunder
    6
    200.0
    5.0
    205.0
    —
    $ 15

         Coal Creek
    7
    126.5
    1.2
    127.7
    —
      11

       Other Campbell County
    8
    266.0
    10.4
    276.4
    —
      13

      Total Wyoming

    592.5
    16.6
    609.1
    —

    Total Thermal Coal

    665.1
    303.9
    969.0

    Total Coal

    772.9
    442.9
    1,215.9

 (1) Mid-Vol

 (2) High-Vol

 (3) 11,390 Btu/lb; 0.9 lb SO2/Mbtu

 (4) 11,565 BTU/lbs, 9.7 lbs. SO2/MMBTU

 (5) 10,200 - 11,900 BTU/lbs; 6.1 - 9.3 lbs. SO2/MMBTU

 (6) 8,985 BTU/lbs.; 0.6 lbs. SO2/MMBTU

 (7) 8,175 BTU/lbs.; 0.8 lbs. SO2/MMBTU

 (8) 8,200 – 9,100 BTU/lbs.; 0.6 - 0.9 lbs. SO2/MMBTU

 (9) The estimation of Mineral Resources involves assumptions about future commodity prices and technical mining matters. Resources are
not mineral reserves and do not have demonstrated economic viability.

 (10) For Metallurgical coal properties, realized coal prices are based on a combination of coking coal products and thermal products (middlings).
For Thermal coal properties, realized coal prices are based on the expected coal quality. Annually, we consider current and forward-looking
market analysis, various published coal indices and other forecasted pricing from third party analysts and pricing services to establish
the realized coal prices for our coal products, adjusting for transportation costs within our life of mine plan. The realized coal prices
are used in our annual five-year budgeting process and the realized coal price is then held constant after year five to the end of the
mine life.

The following table shows our estimates of Mineral
Reserves as of December 31, 2023, prepared in accordance with Subpart 1300 of Regulation S-K.

Total Mineral Reserves

(Tons in millions)

    Representative
    Recoverable Mineral

Reserves

     Coal
    Quality
    (million
    tons)

    Realized
    Coal
    Recovery

    Product / Region
    / Mine

    Proven(7)
    Probable(7)
    Total(7)
    Price(8)
    Factor %

    Metallurgical Coal

       Central Appalachia

          Beckley
    1
    21.9
    3.4
    25.3
    $ 153
      39 %

          Mountain Laurel
    3
    9.3
    7.3
    16.6
      144
      32 %

          VA, Royalty
    2
    0.4
    —
    0.4
      —
      —

       Total Central Appalachia

    31.6
    10.7
    42.3

      Northern Appalachia

         Leer
    3
    11.4
    24.7
    36.1
    $ 161
      42 %

         Leer South
    3
    44.7
    18.0
    62.7
      150
      44 %

        Other Northern Appalachia
    3
    47.8
    31.0
    78.8
      157
      39 %

      Total Northern Appalachia

    103.9
    73.7
    177.6

    Total Metallurgical Coal

    135.5
    84.4
    219.9

    Thermal Coal

      Colorado

          West Elk
    4
    35.0
    3.2
    38.2
    $ 65
      98 %

      Illinois Basin, Royalty
    5
    137.9
    33.5
    171.4
      —
      —

      Wyoming

         Black Thunder
    6
    419.0
    1.0
    420.0
      15
      100 %

      Total Wyoming

    419.0
    1.0
    420.0

    Total Thermal Coal

    591.9
    37.7
    629.6

    Total Coal

    727.4
    122.1
    849.5

 (1) Low-Vol

 (2) Mid-Vol

 (3) High-Vol

 (4) 11,500 BTU/lbs.; 0.90 lbs. SO2/MMBTU

 (5) 11,200 BTU/lbs.; 4.95 lbs. SO2/MMBTU

 (6) 8,900 BTU/lbs.; 0.66 lbs. SO2/MMBTU

 (7) The Mineral Reserve estimates with respect to our mines have been prepared by the qualified persons referred to herein.

 (8) For Metallurgical coal properties, realized coal prices are based on a combination of coking coal products and thermal products (middlings).
For Thermal coal properties, realized coal prices are based on the expected coal quality. Annually, we consider current and forward-looking
market analysis, various published coal indices and other forecasted pricing from third party analysts and pricing services to establish
the realized coal prices for our coal products, adjusting for transportation costs within our life of mine plan. The realized coal prices
are used in our annual five-year budgeting process and the realized coal price is then held constant after year five to the end of the
mine life.

With respect to cut-off grade, our disclosures include representative
coal qualities, which do not rapidly change across the individual properties.

Exhibits to be included in 10-K.

96.2, page 99

 3. We have the following observations regarding your technical report summary for the Leer South Complex, prepared by Marshall Miller
and Associates, Inc. and dated February 2024. Please consult with your qualified person and tell us how you plan to address each of these
items. In you do not concur with any of these observations please explain in your response.

Disclose the name or number of each title, claim, mineral
right, lease or option under which the property is held and describe the mineral rights, as required by Item 601(b)(96)(iii)(B)(3)(iii)
 & (iv) of Regulation S-K. At a minimum this disclosure should summarize property contracts, royalty payments, mineral rights, and
expiration dates.

Response:

We respectfully acknowledge the Staff’s comment and will revise
future filings with respect to our technical report summary (“TRS”) to address the Staff’s comment above. In order to
meet the requirements of 601(b)(96)(iii)(B)(3)(iii) & (iv) of Regulation S-K, our qualified person (“QP”) will include
the following language and table with regards to mineral control.

Lower Kittanning mineral rights are controlled by eighteen (18) coal
leases and fourteen (14) coal deeds, and there are currently no mineral options in place. Annual lease payments for the coal leases range
from Forty Dollars ($40) up to Fifty-Thousand Dollars ($50,000) per year. Payments are made in order to maintain the respective leases,
and all payments are recoupable against future mining. The terms of all leases, with the exception of L-18, are until exhaustion of the
mineable and merchantable coal. Production royalty rates range from four percent (4%) to seven percent (7%) of the gross sales price (GSP).

    File
    ID
    Document
    Type
    Expiration
    Date
    Seam
    Description

    L-1
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-2
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-3
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-4
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-5
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams except Pittsburgh

    L-6
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-7
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-8
    Coal Lease
    Exhaustion of mineable and merchantable coal
    Kittanning Seam

    L-9
    Coal Lease
    Exhaustion of mineable and merchantable coal
    Kittanning Seam

    L-10
    Coal Lease
    Exhaustion of mineable and merchantable coal
    Upper and Lower Kittanning Seams

    L-11
    Coal Lease
    Exhaustion of mineable and merchantable coal
    Clarion and Lower Kittanning Seams

    L-12
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams except Pittsburgh and above

    L-13
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams except Pittsburgh Seam

    L-14
    Coal Lease
    Exhaustion of mineable and merchantable coal
    Clarion and Kittanning Seams

    L-15
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-16
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams

    L-17
    Coal Lease
    Exhaustion of mineable and merchantable coal
    All Seams except Pittsburgh and above

    L-18
    Coal Lease
    1/21/2029
    Clarion and Kittanning Seams

    D-1
    Deed
    N/A
    All Seams

    D-2
    Deed
    N/A
    All Seams except Pittsburgh and above

    D-3
    Deed
    N/A
    All Seams

    D-4
    Deed
    N/A
    All Seams

    D-5
    Deed
    N/A
    Kittanning Seam

    D-6
    Deed
    N/A
    Kittanning Seam

    D-7
    Deed
    N/A
    Clarion Seam

    D-8
    Deed
    N/A
    Kittanning Seam

    D-9
    Deed
    N/A
    All Seams

    D-10
    Deed
    N/A
    All Seams except Pittsburgh and above

    D-11
    Deed
    N/A
    All Seams

    D-12
    Deed
    N/A
    All Seams

    D-13
    Deed
    N/A
    All Seams

    D-14
    Deed
    N/A
    All Seams

    D-11
    Deed
    N/A
    All Seams

    D-12
    Deed
    N/A
    All Seams

    D-13
    Deed
    N/A
    All Seams

    D-14
    Deed
    N/A
    All Seams

Disclose the current and future permitting requirements
as required by Item 601(b)(96)(iii)(B)(3)(v) of Regulation S-K.

Response:

We respectfully acknowledge the Staff’s comment. Information
pertaining to permitting needs is currently contained in Section 17 of the TRS. In future filed TRSs, our QP will expand Section 3 of
the TRS to provide additional information of future permitting requirements and conditions to satisfy Item 601(b)(96)(iii)(B)(3)(v) of
Regulation S-K. An example of the proposed disclosure is shown below.

Current state mining reclamation permits extend through 2027 for most
surface infrastructure and 2028 for the refuse impoundment. The extension of such permits will be required to execute the mine plan through
reserve exhaustion, which is projected to occur in 2042. Existing impoundment permitting and extensions are sufficient to contain volumes
of coarse and fine refuse material projected to be produced through reserve exhaustion.

Include Appendix C, which is referenced on page 47 with
respect to the footprint of the LOM plan.

Response:

We respectfully acknowledge the Staff’s comment. The reference
to Appendix C should have been removed from the published version of the TRS. We note that Item 601(b)(96)(iii)(B)(13)(v) of Regulation
S-K requires the inclusion of a final map outline, which is included as Figure 13-1 in the TRS. For your convenience, we have inserted
the same figure below. We believe this map satisfies the requirements of Item 601(b)(96)(iii)(B)(13)(v) of Regulation S-K. Our QP will
remove the reference to Appendix C in future filed TRSs.

Revise to remove uncontrolled tonnage from the
reserve table.

Response:

We respectfully acknowledge the Staff’s comment. Because the
uncontrolled tonnage must be acquired to execute the LOM plan, we believe it is helpful to include such tonnage in some capacity. Upon
further reconciliation of tonnages and properties during our review, we respectfully advise that uncontrolled tonnages within our LOM
plan are in the range of 5.5 million tons.