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    ArentFox Schiff LLP

1717 K Street NW
 Washington, DC 20006

    202.857.6000       main

    202.857.6395       fax

    afslaw.com

October 8, 2024

    Ms. Sondra Snyder
 Mr. Karl Hiller
 Division of Corporation Finance
 United States Securities and Exchange Commission
 100 F St NE
 Washington, DC 20549
    Ralph De Martino

Partner

(202) 724-6848    direct

rdemartino@afslaw.com

    Re:
    Ramaco Resources, Inc.

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

    Filed March 14, 2024

    File No. 001-38003

Dear Ms. Snyder and Mr. Hiller:

This firm serves as outside counsel to Ramaco Resources, Inc. (“Ramaco”).
This is in response to your letter (the “Comment Latter”) addressed to Mr. Randall Atkins, Chief Executive Officer, Ramaco
dated September 20, 2024. The Comment Letter sets forth two comments. The Staff’s comments and Ramaco’s responses are set
forth below:

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

Properties, page 66

1. Please submit the revisions that you propose to address the requirement
                                            in Item 1304(d)(1) of Regulation S-K (footnote 1 to the illustrations), to include the mineral
                                            prices and the points of reference associated with the determinations of your mineral resources
                                            and mineral reserves along with the associated tabulations.

Registrant’s Response: On October 2, 2024,
Scott Spears, the Executive Vice President of Planning and Analysis of Ramaco and Tom Blandford, Executive Vice President, Weir International,
Inc. (“Weir”), an independent engineering firm engaged by Ramaco that prepared studies of Ramaco’s coal reserves for
the Elk Creek Complex, Berwind Complex, and Knox Creek Complex had dialogue via telephone with John Coleman, the Staff’s Mining
Engineer. Messrs. Spears and Blandford informed Mr. Coleman that in the future Ramaco intended to add the following footnote to Item
2. Properties. Table 1 in the Ramaco Annual Reports on Form 10-K:

Resource probable economic mineability is based on underground
minable resources with 2.0 feet minimum seam thickness, surface and highwall mines with 1.0 feet minimum seam thickness, area mining
with a cutoff stripping ratio of 20:1, and primarily metallurgical low and mid-volatile coal at the Berwind Complex realizing a sales
price of $169 per ton at a cash cost of $101 per clean ton (FOB Mine), primarily metallurgical mid and high-volatile at the Knox Creek
Complex realizing a sales price of $184 per ton and cash cost of $99 per clean ton (FOB Mine), and primarily metallurgical high-volatile
A and high-volatile B coal at the Elk Creek Complex realizing a sales price of $131 per ton at a cash cost of $77 per clean ton (FOB
Mine).

Smart In
 Your World®

    Ms. Sondra Snyder
 Mr. Karl Hiller

    October 8, 2024
 Page 2

In addition, Messrs. Spears and Blandford informed Mr.
Coleman that Ramaco intended to add the following footnote to Item 2. Properties. Table 2 in the Ramaco Annual Reports on Form 10-K:

Mineral Reserves estimated for the Berwind Complex are
based primarily on metallurgical low and mid-volatile coal realizing a sales price of $169 per ton at a cash cost of $101 per clean ton
(FOB Mine), primarily metallurgical mid and high-volatile coal at the Knox Creek Complex realizing a sales price of $184 per ton and
cash cost of $99 per clean ton (FOB mine), and primarily a metallurgical high-volatile A and high-volatile B coal at the Elk Creek Complex
realizing a sales price of $131 per ton at a cash cost of $77 per clean ton (FOB Mine).

At the conclusion of the dialogue Mr. Coleman informed
Mr. Spears that Ramaco should include the above-referenced footnotes with the mineral prices and points of reference related to Ramaco’s
mineral resources and mineral reserves in the Properties section of each Annual Report on Form 10-K, on a go-forward basis (i.e., in
the Annual Report on Form 10-K for the fiscal year ending December 31, 2024 and thereafter), and that no revisions to the Annual Report
on Form 10-K for the fiscal year ended December 31, 2023 would be required.

    Ms. Sondra Snyder

Mr. Karl Hiller

October 8, 2024
 Page 3

Controls and Procedures, page 119

2. We note your disclosure stating that your officers concluded
that internal control over financial reporting was not effective at the end of the year due to a material weakness involving a "pervasive
lack of sufficient documentation of accounting policies, procedures, and controls...[which] does not allow management to effectively
assess its relevant risks and key controls to
properly test for design and operating effectiveness."

We also note disclosure on page
31 of your 2024 second quarter interim report indicating that you have not resolved the material weakness and have only begun to
develop a plan of remediation, which you expect will include "assessing, redesigning, and implementing modifications of [your]
internal controls" and based on your commentary it appears that you are anticipating this will involve an extended period of
time to accomplish. Given these disclosures explain to us how your officers are able to support the representations made in the
certifications at Exhibits 31.1 and 31.2, in both the annual and subsequent interim reports, stating that such officers have
designed or supervised the design of internal control over financial reporting "...to provide reasonable assurance regarding
the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with
generally accepted accounting principles."

Registrant’s Response: The undersigned had
telephonic dialogue with Ms. Sondra Snyder on September 23, 2024 and with Mr. Karl Hiller on September 24, 2024. I informed the Staff
that Ramaco had concluded, at the time of filing of the Annual Report on Form 10-K for the fiscal year ended December 31, 2023, that
internal control over financial reporting was not effective at the end of the year due to a material weakness relating primarily to the
sufficiency of the documentation of the control procedures utilized. I further informed the Staff that the weakness was raised by the
national office of its former auditor in connection with the former auditor’s audit of Ramaco’s financial statements for
the year ended December 31, 2023 and that the weakness related primarily to Ramaco’s documentation of the procedures utilized -
- notwithstanding that the audit team of the former auditor had observed the periodic implementation of the control procedures during
the year and had repeatedly informed Ramaco that they viewed the procedures to be adequate. Stated more succinctly, the issue raised
by the national office of the former auditor related more to the adequacy of the documentation of the control procedures employed, rather
than the adequacy of the procedures themselves. The officers that executed the certifications set forth in Exhibits 31.1 and 31.2 are
comfortable that Ramaco’s internal control over financial reporting provides reasonable assurance regarding the reliability of
Ramaco’s financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted
accounting principles; and the certifying officers are therefore comfortable with the representations made by them in the certifications
at both the annual and subsequent interim reports and the support therefor. Ramaco believes that the procedures themselves are adequate
and it is in the process of revising them to provide more fulsome documentation and recordation of the application of those procedures
on an ongoing basis.

    Ms. Sondra Snyder
 Mr. Karl Hiller

    October 8, 2024
 Page 4

Finally, I hereby reiterate the representations that I made
to the Staff at Ramaco’s direction during my telephone conversation with Mr. Hiller on September 24, 2024 that Ramaco intends to
have its revised internal control over financial procedures in place at the end of the third fiscal quarter, and further expects that
thereafter it will take approximately two quarters of testing and verification to reach a determination that those procedures are effective.
My understanding of the dialogue I had with Mr. Hiller on September 24, 2024 is that no modification of the Annual Report on Form 10-K
for the fiscal year ended December 31, 2023 is required in response to this comment.

* * * * *

If you have any further questions or comments please feel free to
contact the undersigned by telephone at (202) 744-6848 or by email at ralph.demartino@afslaw.com.

We would like to express our sincere gratitude to the Staff for the
time it has spent with Ramaco and Ramaco’s representatives as we have attempted to resolve the above-referenced comments.

Respectfully submitted,

Ralph V. De Martino

RD/sw