SecProbe.io

Mail Stop 3561
        January 9, 2017

Via E -mail
Michael Bauersachs
Chief Executive Officer
Ramaco Resources,  Inc.
250 West Main Street, Suite 210
Lexington, Kentucky 40507

Re: Ramaco Resources,  Inc.
Registration Statement on Form S -1
Filed December 29, 2016
  File No. 333 -215363

Dear Mr.  Bauersachs :

We have reviewed your registration statement  and have the following comments.  In
some of our comments, we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter by amending your registration statement and providing the
requested information .  If you do not believe our comments apply to your facts and
circumstanc es or do not believe an amendment is appropriate, please tell us why in your
response.

After reviewing any amendment to your registration statement and the information you
provide in response to these  comments, we may have  additional comments.

Summa ry Reserve Data, page 7
Business, page 72

1. We note your disclosure now includes mineral reserves for your Knox Creek property
and that you have updated your technical reports for your Elk Creek property. Please
forward to our engineer as supplemental infor mation and not as part of your filing, your
Knox Creek Property Reserve Study dated December 19, 2016, your Elk Creek Property
Reserve and Resource Study dated December 29, 2016, and your Reasonableness Review
Study Elk Creek Mining Operations December 201 6.

Please provide this information on a CD, formatted as Adobe PDF files.  You may ask to
have this information returned by making a written request at the time it is furnished, as
provided in Rule 418(b) of Regulation C.

Michael Bauersachs
Ramaco Resources,  Inc.
January 9, 2017
Page 2

2. We note your disclosure on pages  7, 82, and 83 indicating that your Knox Creek
production forecast and mine plan are under development and the estimated cost of
production is unavailable.   Please tell us why this information is not available even
though you have declared reserves for th is property.  In this regard we note your
disclosure on page 2 stating that reserves are economically recoverable at a price in
excess of cash costs to mine the coal and fund ongoing replacement capital.

Use of Proceeds , page 53

3. Given the proposed size o f the offering , please revise the disclosure in this section, in
accordance with your response to comment 16 in your letter dated December 12, 2016.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their d isclosures, notwithstanding any review, comments, action or absence of
action by the staff.

Refer to Rules 460 and 461 regarding requests for  acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date  of the registration
statement.

You may contact  Myra Moosariparambil , Staff Accountant, at (202) 551 -3796  or Craig
Arakawa, Accounting Branch Chief, at (202) 551 -3650  if you have questions regarding
comments on the financial s tatements and related matt ers.  Please contact John Coleman, Mining
Engineer at (202) 551 -3610 with any engineering related questions.  Please contact Ruairi Regan
at (202) 551 -3269 or  Pamela Howell, Special Counsel,  at (202) 551 -3357  with any other
questions.

     Sincerely,

        /s/ John Reynolds

     John Reynolds
Assistant Director
Office of Beverages,
Apparel and Mining

cc:  Douglas E. McWilliams, Esq.
       Vinson & Elkins LLP