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intrepidpotash.com

October 30, 2023

Office of Energy & Transportation

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549

Re:          Intrepid
Potash, Inc.

Form 10-K for the Fiscal Year ended December 31,
2022

Filed March 7, 2023

File No. 001-34025

Ladies and Gentlemen:

This letter is in response to your letter dated September 15,
2023, setting forth comments from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”)
on Intrepid Potash, Inc.’s Annual Report on Form 10-K for the year ended December 31, 2022 (the “Form 10-K).
In this letter, we have recited the Staff's comments in italicized, bold type and have followed each comment with our response. Capitalized
terms used herein and not otherwise defined herein have the meanings assigned to such terms in the Form 10-K.

Form 10-K for the Fiscal Year ended December 31, 2022

Properties

Overview of Properties, page 32

 1. Please expand your disclosures under the Overview sections on pages 32, 38, and 43 to include the book value of each material
property to comply with Item 1304(b)(2)(iii) of Regulation S-K.

Response:
We respectfully acknowledge the Staff’s comment, and we will expand our disclosure in future filings to include the net book value
of each of our material properties. As of December 31, 2022, the net book value of our material properties was as follows:

New Mexico Property - $172.3 million

Moab Property - $62.6 million

Wendover Property - $41.0 million

Leases and Permits, page 35

 2. Please expand your disclosures under Leases and Permits on pages 35, 40, and 45 to describe the royalty payments and associated
rates pertaining to federal and state lands for each material property to comply with Item 1304(b)(1)(iii) of Regulation S-K.

Response:
We respectfully acknowledge the Staff’s comment, and we will expand our disclosure in our future fillings to include additional
information regarding royalty payments and rates in the “Leases and Permits” sections for each material property, as set forth
below.

New Mexico Facilities - Leases and Permits

We control the right to mine approximately 143,000 acres
in New Mexico. Of that acreage, we lease 32,000 acres from the State of New Mexico, 106,000 acres from the federal government through
the Bureau of Land Management (“BLM”), and 300 acres from private owners. We own 4,700 surface acres near the mine site, adjacent
to the federal and state mining leases. Most mining operations are on properties leased from the State of New Mexico or the federal government.
These leases generally contain stipulations that require us to commence mining operations within a specified term and to continue mining
to retain the lease. The stipulations on our leases are subject to periodic readjustment by the State of New Mexico and the federal government.
Federal leases are for indefinite terms subject to readjustment of the lease stipulations, including the royalty payable to the federal
government, every 20 years. Royalty payments equal a percentage of product sales less freight. Most of our leases with the federal government
stipulate a five percent royalty rate. However, certain federal leases contain a sliding scale royalty rate of a minimum of two percent
and up to a maximum of five percent based on the grade of ore extracted under the lease. In 2022, IPNM paid royalties of $7.2 million
to the federal government.

Our leases with the State of New Mexico are issued for terms
of 10 years and for as long thereafter as potash is produced in commercial quantities and are subject to readjustment of the lease stipulations,
including the royalty payable to the state. Royalty payments equal a percentage of product sales less freight. Our leases with the State
of New Mexico stipulate a five percent royalty rate. In 2022, IPNM paid royalties of $2.7 million to the State of New Mexico.

Moab Property – Leases and Permits

At our Moab facility, we lease approximately 10,100 acres
from the State of Utah and approximately 200 acres from the federal government through the BLM. We own approximately 3,800 surface acres
overlying and adjacent to portions of acres leased from the State of Utah. These leases generally contain stipulations that require us
to commence mining operations within a specified term and to continue mining to retain the leases.

Our lease with the federal government is for an indefinite
term subject to readjustment of the lease stipulations, including the royalty payable to the federal government. Royalty payments equal
a percentage of product sales less freight. The current royalty rate stipulated in the federal lease is five percent. In 2022, Moab made
no royalty payments to the federal government.

Our Moab leases with the State of Utah are for terms of 10
years subject to extension and possible readjustment of the lease stipulations, including the royalty payable to the State of Utah. Our
Moab leases with the State of Utah are operated as a unit under a unit agreement with the State of Utah, which extends the terms of all
the Moab state leases as long as operations are conducted on any portion of these state leases. Our Moab leases with the State of Utah
are currently extended until 2024 or so long as potash is being produced and stipulate royalty rates between 4.25% and 5.00%. In 2022,
Moab paid $2.6 million of royalties to the State of Utah.

Wendover Property – Leases and Permits

We own approximately 57,500 acres of the Wendover site. The
BLM and the State of Utah own approximately 32,800 acres of the Wendover site, which we lease (excluding lands used for highway and utility
purposes).

We hold leases from the federal government that include 24,700
acres adjoining the Wendover property to the east. Our Wendover federal leases have an indefinite term subject to readjustment of the
lease stipulations, including the royalty payable to the federal government. Royalty payments equal a percentage of product sales less
freight. The current royalty rate stipulated in the federal leases is three percent. In 2022, Wendover made $0.3 million in royalty payments
to the federal government.

The State of Utah owns several state land trust sections
within the Wendover property site boundaries. We lease approximately 8,100 acres of property from the State of Utah under special use
and mineral leases. The Wendover state leases are interspersed among our property and the Wendover federal leases. The Wendover state
leases are for an indefinite term subject to readjustment of the lease stipulations, including the royalty payable to the State of Utah.
Royalty payments equal a percentage of product sales less freight. The current royalty rate stipulated in our Wendover state leases is
four percent. In 2022, we made $0.1 million in royalty payments to the State of Utah.

IPNM - Summary of Potash Mineral Reserves, page 37

 3. We note that disclosures of your reserves In-place, KCL, ROM Ore, and Sylvinite brine tonnages appear to represent estimates
of your final product adjusted possibly for geologic factors, plant recovery, product purity, and/or cavern losses.

However, this tonnage quantity appears to be unrelated
to your grade disclosure and different from your resource tonnage disclosures.

Please revise as necessary to state the tonnage and
grade of your reserves in alignment with your resource disclosures, or provide additional disclosure for your chosen metrics to include
explanations of how these quantities were calculated or determined to comply with Item 1304(d)(1) of Regulation S-K.

Response:
We respectfully acknowledge the Staff’s comment, and we will expand our disclosure in our future fillings to include additional
information to describe how product tonnages are calculated from either the In-Place KCl or ROM Ore of our reserves, as follows:

IPNM - Summary of Potash Mineral Reserves effective December 31,
2022 based on 325 $/Product Ton Mine Site

    In-Place KCl
    In-Situ Grade1
    Product2
    Brine Cutoff Grade3

    (Mt)
    (%K2O)
    (Mt)
    (%K2O)
    Processing Recovery (%)

    Proven Mineral Reserves
      5.4
      21.7
      4.3
      2.0
    85

    Probable Mineral Reserves
      0.3
      19.1
      0.2
      2.0
    85

    Total Mineral Reserves
      5.7
      21.6
      4.5

IPNM - Summary of Langbeinite Mineral Reserves effective December
31, 2022 based on 340 $/Product Ton Mine Site

    ROM Ore4
    In-Situ Grade5 (Diluted)
    Product6
    Cutoff Grade

    (Mt)
    (%K2O)
    (Mt)
    (%K2O)
    Processing Recovery (%)

    Proven Mineral Reserves
      17.3
      8.6
      4.6
      43
    68

    Probable Mineral Reserves
      4.2
      9.1
      1.2
      43
    68

    Total Mineral Reserves
      21.5
      8.7
      5.8

1In-situ grade is the amount of K2O in the contact
area of the caverns and is used to calculate the In-Place KCl

2Product is calculated by multiplying In-Place KCl by: dissolution
factor of 96%, areal recovery of 100%, geologic factor of 94.2%, plant recovery of 85%, cavern loss factor of 98%, and a product purity
factor of (1/.95)

3Brine cutoff grade is the amount of K2O in the
extracted brine necessary to cover the cash costs of production.

4ROM Ore is reported based on a detailed conventional
mine plan adjusted for random impurities of 10%

5In-situ grade (diluted) is the amount of K20 in the ore
body with consideration for dilution occuring during mining.

6Product tons are calculated by multiplying ROM Ore by:
the In-Situ Grade (Diluted)/22.70%, plant recovery of 68%, and a product purity factor of (1/.944). In-situ Grade (Diluted) is divided
by 22.70% to convert K20 grade to pure langbeinite by mass.

Mineral Reserves were prepared effective December 31, 2021, by Agapito Associates,
Inc., a qualified firm for the estimate and independent of Intrepid, and updated to December 31, 2022, by Intrepid to account for depletion
that occurred due to 2022 mining operations.

Mineral Reserves are reported exclusive of Mineral Resources, on a 100% basis.

Mt = million tons, % = percentage, K2O = potassium
oxide, ft = feet

We note an immaterial clerical error in the calculated
potash product tons as of December 31, 2022, which was reported as 4.0 Mt. The potash product tons calculation erroneously
excluded the product purity factor adjustment. The correct potash product tons as of December 31, 2022 is 4.3 Mt. and will be
updated appropriately in future filings.

Financial Statements

Note 17 - Business Segments, page 98

 4. You state that your segment measure of profitability is segment gross margin which you reconcile to consolidated gross margin;
and indicate that you do not allocate other operating expenses or non-operating income and expenses to your reportable segments.

Please revise your presentation as necessary to include
a reconciliation of your segment measure of profitability to consolidated income before income taxes and discontinued operations as required
by ASC 280-10-50-30.

Response:
We respectfully acknowledge the Staff’s comment and in future filings we will add additional narrative information to our segment
footnote to achieve the requirements of ASC 208-10-50-30 to reconcile segment measure of profitability to consolidated income before taxes
as provided below:

“Our operations are organized into three segments:
potash, Trio®, and oilfield solutions. The reportable segments are determined by management based on several factors including
the types of products and services sold, production processes, markets served and the financial information available for our chief operating
decision maker. We evaluate performance based on the gross margins of the respective business segments and do not allocate other operating
expenses or non-operating income and expenses to our reportable segments. Segment gross margins are reconciled to consolidated gross margins
in the segment tables. To reconcile segment gross margins to consolidated income before taxes, consolidated operating expense amounts
and consolidated other income and expense amounts, expenses are subtracted from and income is added to consolidated gross margin to arrive
at consolidated income before taxes, as shown on the statement of operations.”

Exhibits

Technical Report Summaries

General, page EA-1

 5. We have reviewed exhibits 96.1, 96.2, and 96.3 and have several comments that pertain to all three documents which immediately
follow this general comment. This group of comments is followed by additional comments that are specific to the exhibits individually,
as indicated. We expect that you will need to obtain and file revised exhibits to address the concerns identified in these comments.

Please consult with the qualified persons involved
in preparing those reports in conjunction with formulating your response. We suggest that you submit draft revisions for review prior
to filing the revised reports.

Response:
We respectfully acknowledge the Staff’s comments on Exhibits 96.1, 96.2, and 96.3 and we will update such exhibits, as necessary,
as discussed below. We will file the revised exhibits with our Annual Report on Form 10-K for the year ended December 31, 2023
(the “Revised Exhibits”). Prior to filing the Revised Exhibits, we will provide draft revisions to the Staff for review.

Section 6: Geologic Setting, page EA-6

 6. The disclosures concerning mineralization should include at least one stratigraphic column and one cross-section of the local
geology to comply with Item 601(b)(96)(iii)(B)(6)(iii) of Regulation S-K.

Response:
We respectfully acknowledge the Staff’s comment, and we will update our disclosures with respect to mineralization in the Revised
Exhibits, as shown below.

We respectfully direct the Staff to Figure 6-1 in Section 6.3
 “Property Geology” in Exhibit 96.1 that shows the cross section for the local geology of the Carlsbad, New Mexico Potash
District, and Figure 6-2 in Exhibit 96.1 that shows a typical stratigraphic column Ochoan Series of the Permian Basin.

We acknowledge that we included the stratigraphic column
in Exhibit 96.2 twice and did not include a cross-section of the local geology. Figure 6-2 of Exhibit 96.2 is correctly labeled
as the “Paradox Basin Cross Section,” but the image provided is a stratigraphic column for the Paradox Basin. Figure 6-5 is
also a stratigraphic column. We will replace Figure 6-2 with the graphic shown below in the revised Exhibit 96.2:

Figure
6-2. Paradox Basin Cross Section (after Stevenson and Barrs 1986)

We respectfully direct the Staff to Figure 6-3 in Section 6.1
 “Regional. Local, and Property Geology” in Exhibit 96.3 that shows the stratigraphic column for the Intrepid-Wendover
facility.

The cross-section of the property is included in Figure 13-1
of Exhibit 96.3. Within Section 6.3 of Exhibit 96.3, we will include a reference to see Figure 13-1 for the cross-section
of the local geology.

Section 12: Mineral Reserve Estimates, page EA-12

 7. We note that disclosures of your reserves In-place, KCL, ROM Ore, and Sylvinite brine tonnages appear to represent estimates
of your final product adjusted possibly for geologic factors, plant recovery, product purity, and/or cavern losses.

However, this tonnage quantity appears to be unrelated
to your grade disclosure and different from your resource tonnage disclosures.

Please revise as necessary to state the tonnage and
grade of your reserves in alignment with your resource disclosures, or provide additional disclosure for your chosen metrics to include
explanations of how these quantities were calculated or determined to comply with Item 601(b)(96)(iii)(B)(12)(i) and (ii) of
Regulation S-K.

Response:
We respectfully acknowledge the Staff’s comment, and we will update Table 12-5 in t