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                          DIRECT

                          DIRECT FAX

                          EMAIL

    Howard
    Groedel

    Partner

    216.583.7118

     216.583.7119

     hgroedel@ubglaw.com

    October
15, 2024

VIA
EDGAR SUBMISSION

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Real Estate & Construction

100
F Street, N.E.

Washington,
D.C. 20549

Attn:
Ruari Regan and David Link

Office
of Real Estate & Construction

    Re:
    Range
    Impact, Inc.

    Amendment
    No. 1 to Annual Report on Form 10-K

    Amendment
    No. 1 to Quarterly Report on Form 10-Q

    Filed
    August 8, 2024

    File
    No. 000-53832

    BOCA RATON

    CHICAGO

    CINCINNATI

    CLAYTON, MO

    CLEVELAND

    COLUMBUS, OH

    NEW YORK

    SO. ILLINOIS

    ST. LOUIS

    WASHINGTON, DC

    UBGLAW.COM

    Ladies and Gentlemen:

    This letter is submitted on behalf of Range Impact, Inc. (the “Company”) in response to the comments of the staff of the Division of Corporation Finance (the “Staff”) with respect to the Company’s Amendment No. 1 to Annual Report on Form 10-K and Amendment No. 1 to Quarterly Report on Form 10-Q, both of which were filed on August 8, 2024 (respectively, “Form 10-K/A” and “Form 10-Q/A”), as set forth in your letter dated October 3, 2024 addressed to Michael Cavanaugh, Chief Executive Officer of the Company (the “Comment Letter”).

    For reference purposes, the text of the Staff’s comment has been reproduced herein with a response to the numbered comment.

    The responses provided herein are based upon information provided to UB Greensfelder LLP by the Company.

    Amendment No. 1 to Annual Report on Form 10-K:

Mine
Safety Disclosure, page 36

      1. We
                                            note your response to prior comment 1 that you ceased being the operator of a coal or other
                                            mine effective December 29, 2023, and therefore, no disclosures under Item 104 of Regulation
                                            S-K were required in filings for periods after such date. Please reconcile this response
                                            with your disclosure in your Form 10-Q, filed August 14, 2024, regarding your statement that
                                            Range Minerals subcontracted mining activities and that on May 1, 2024, Range Minerals contracted
                                            with a mining contractor at the Fola mining site in West Virginia. It appears, based on these
                                            disclosures that you continue to conduct mining activities. Please provide the Mine Safety
                                            Disclosure required by Item 4 in Part II of Form 10-Q or explain how you concluded such disclosure
                                            is not required.

    1660
                           West 2nd Street

    Suite
    1100

    Cleveland,
    OH 44113-1406

    FIRM     	216.583.7000
    FAX     	216.583.7001

United
States Securities and Exchange Commission

October
15, 2024

Page
2

RESPONSE:
In response to the Staff’s comment, on October 15, 2024, the Company filed (i) Form 10-Q/A Amendment No. 2 for the quarterly period
ending March 31, 2024 and (ii) a Form 10-Q/A for the quarterly period ending June 30, 2024, disclosing in Item 4 in Part II of both filings
the information required by Item 104 of Regulation S-K.

Form
10-Q/A filed August 8, 2024

Restatement
of Previously Reported Financial Statements, page 13

    2. We
                                            note that you reported a significant restatement to your reported Cost of Services as of
                                            March 31, 2024. Please clarify to us how you evaluated the current report requirements under
                                            Item 4.02 of Form 8-K or file any required current reports as needed.

RESPONSE:
We acknowledge the Staff’s comment. We further acknowledge that the Securities Exchange Act of 1934, as amended (the “Exchange
Act”), requires the Company to file a report on Form 8-K upon the occurrence of any one or more events specified in the items in
Sections 1-6 and 9 of that form, including Item 4.02 Non-Reliance on Previously Issued Financial Statements or a Related Audit Report
or Completed Interim Review. The Company inadvertently failed to file a timely current report as required by Form 8-K. On October 15,
2024, the Company filed a Form 8-K disclosing the information required by Item 4.02.

    Very truly yours,

    /s/ Howard Groedel

    Howard Groedel