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CORRESP

 Solaris Oilfield Infrastructure, Inc.

9651 Katy Freeway, Suite 300

Houston, Texas 77024

August 7, 2024

 Division of Corporation Finance

Office of Technology

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549-3561

Re:
 Solaris Oilfield Infrastructure, Inc.

Preliminary Proxy Statement on Schedule 14A

Filed July 26, 2024

 File No. 001-38090

 Ladies and Gentlemen:

Set forth below are the responses of Solaris Oilfield Infrastructure, Inc. (the “Company”, “we,” “us” or
“our”), to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) by letter dated August 6, 2024, with respect to
Preliminary Proxy Statement on Schedule 14A, File No. 001-38090, filed with the Commission on July 26, 2024 (the “Preliminary Proxy”). Based on telephonic correspondence with the Staff on
August 7, 2024, the Company intends to submit its definitive proxy statement (the “Definitive Proxy”) which shall contain the edits discussed in our responses hereto via EDGAR.

For your convenience, each response is prefaced by the exact text of the Staff’s corresponding comment in bold, italicized text. All
references to page numbers and captions correspond to the Preliminary Proxy unless otherwise specified.

 Preliminary Proxy Statement on Schedule 14A

 Certain Solaris Unaudited Forecasted Financial Information, page 80

1.
 We note your disclosure that you project the total revenue of Mobile Energy Rentals LLC to increase from
$52 million in 2024 to $134 million in 2025. Please tell us how this is consistent with the company’s historical revenue trends.

RESPONSE: We have revised the Definitive Proxy to address the Staff’s comment through the inclusion therein of the following
additional disclosure:

 Securities and Exchange Commission

August 7, 2024

  Page
 2

2024P (1)

2025P

2026P

2027P

2028P

2029P

 Total Revenue (2)

$
52

$
134

$
167

$
168

$
169

$
166

 Gross Profit (2)

$
43

$
112

$
138

$
138

$
139

$
136

 EBITDA (2)(3)

$
32

$
100

$
124

$
123

$
121

$
116

 Total Capital Expenditures (2)

($
203
)

($
123
)

($
6
)

($
10
)

($
18
)

($
90
)

 End of Year Number of Turbines

25

44

44

44

44

44

 End of Year Fleet Size (MW)

164

478

478

478

478

478

(1)
 2024P includes certain summarized prospective financial information regarding the Company beginning with the
second quarter of 2024.

(2)
 Despite the fact that MER’s historical total revenue decreased slightly from 2022 to 2023 due to shorter
contract terms and lower contract values, the forecasted increase in revenue, gross profit and EBITDA for the periods of 2024 through 2029 takes into account recent contractual arrangements, additional turbine deliveries and overall tightness in the
power supply market. Therefore, as the Company purchases and takes delivery of new equipment it deploys the additional equipment to customers for incremental revenue. The new turbines under purchase order ($307.6mm) are included in the capital
expenditures in 2024 and 2025 with delivery of the last turbine scheduled during Q3 2025.

(3)
 EBITDA is calculated as Gross Profit less Selling, general and administrative expenses and Other operating
expenses.

 The Company intends in the Definitive Proxy to revise page 82 of the Preliminary Proxy in response to
this comment.

2.
 We note your statement on pages 88 and B-4 that the financial
advisor disclaims responsibility “if future results are materially different from projected financial results.” While you may include qualifying language with respect to such projections, it is inappropriate to disclaim responsibility for
this information. Please revise to remove this disclaimer.

 RESPONSE: We have revised the Definitive
Proxy to address the Staff’s comment by removing this disclaimer. Specifically, we have revised the language from the Preliminary Proxy stating that “Piper Sandler does not assume responsibility if future results are materially different
from projected financial results” to instead say in the Definitive Proxy that “Future results may be materially different from projected financial results.” The Company intends in the Definitive Proxy to revise page 88 of the
Preliminary Proxy in response to this comment.

 *  *  *  *  *

 Securities and Exchange Commission

August 7, 2024

  Page
 3

 Please direct any questions that you have with respect to the foregoing or if any additional
supplemental information is required by the Staff, please contact Jackson A. O’Maley of Vinson & Elkins L.L.P. at (713) 758-3374.

Very truly yours,

SOLARIS OILFIELD INFRASTRUCTURE, INC.

By:

 /s/ William Zartler

Name:

William Zartler

Title:

Chief Executive Officer

Cc:
 Christopher M. Powell, Solaris Oilfield Infrastructure, Inc.

Jackson A. O’Maley, Vinson & Elkins L.L.P.