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                              October 31, 2022

       Randall W. Atkins
       Chairman and Chief Executive Officer
       Ramaco Resources, Inc.
       250 West Main Street, Suite 1800
       Lexington, Kentucky 40507

                                                        Re: Ramaco Resources,
Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-3 on Form S-1
                                                            Filed October 12,
2022
                                                            File No. 333-267152

       Dear Randall W. Atkins:

             We have reviewed your amended 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
       circumstances 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
September 26, 2022 letter.

       Amendment No,1 to Registration Statement on Form S-3 on Form S-1

       Summary
       About Ramaco Resources, Inc., page 2

   1.                                                   We note your statement
of 769 million resource tons. This is the sum of only your
                                                        measured and indicated
resources. Please review and modify your filing and report your
                                                        resources as the sum of
your total resources when referring to a general resource tonnage
                                                        or clarify in each
instance, that this resource quantity is only the measured and indicated
                                                        tonnage.
   2.                                                   We note your statement
regarding the ownership of approximately 42 million tons of
                                                        metallurgical coal.
Please modify your filing and identify the property associated with
 Randall W. Atkins
FirstName LastNameRandall W. Atkins
Ramaco Resources, Inc.
Comapany
October 31,NameRamaco
            2022       Resources, Inc.
October
Page 2 31, 2022 Page 2
FirstName LastName
         this tonnage and clarify whether this a reserve or resource quantity.
Coal Royalties, page 2

3.       We note your statement of royalty interests in 38 M tons of reserves
and 473 M tons of
         resources here and elsewhere in your filing. Please review and revise
these quantities as
         necessary to reflect your actual royalty interest in your reserves and
total resources as
         stated in your Form 10-K. Please clarify whether the Amonate tonnage
is a reserve or a
         resource and are the quantities stated here and elsewhere the same as
those related to your
         statement regarding the ownership of approximately 42 million tons of
metallurgical coal.
         Please provide supplementally information that supports your tonnage
quantities, such as
         a compliant S-K 1300 technical report summary.
Pro Forma Cash Available for Dividend, page 4

4.       We have read your response to comment 5. Revise your disclosure to
state that,    The
         Board believes that the anticipated dividend of 20% of the revenue
attributable to the
         CORE Assets is appropriate for investors in Class B common stock and
believe such
         percentage to be sustainable based on commodity prices and production
volumes for the
         foreseeable future.
Carbon Products, page 8

5.       We note your disclosure here and elsewhere related to the Brook
property, which is a
         billion ton deposit, of which you control 162 M tons. Please modify
your filing and
         clarify whether these are resources or reserve tonnages and provide an
S-K 1300
         compliant technical report summary verifying your tonnage estimates.
Recent Developments
Maben Acquisition, page 13

6.       We note your disclosure here and elsewhere related to the Maben
property with 33 M tons
         of coal. Please modify your filing and clarify whether these are
resources or reserve
         tonnages and provide supplementally your information that supports
your tonnage
         quantities, such as a compliant S-K 1300 technical report summary.
7.       Please clarify whether the assets acquired in the Maben Acquisition
will be attributed to
         CORE.
Recent Developments, page 13

8.       We note your disclosure that in connection with closing the Maben
transaction on
         September 23, 2022, Ramaco Development entered into a loan agreement,
pursuant to
         which a lender made a vendor loan to Ramaco Development in the amount
of $21 million
         to be used by Ramaco Development for the sole purpose of paying a
portion of the
         purchase price in said amount to Appleton Coal LLC for the purchase of
Maben pursuant
         to the Purchase Agreement. Please clarify whether this loan will be
attributed to CORE.
 Randall W. Atkins
Ramaco Resources, Inc.
October 31, 2022
Page 3
      If so, expand your disclosure to describe all the material terms of this
loan agreement, and
      file this agreement as an exhibit to your registration statement or tell
us why you believe
      you are not required to do so. Refer to Item 601(b)(10) of Regulation
S-K.
General

9.    We note your response to prior comment 13. You state that you believe
that quarterly
      estimates may be less reliable given your facts and circumstances.
However, you disclose
      an intention to pay specific quarterly dividend amounts. Please refer to
our prior comment
      and expand your disclosure to provide that information.
10.   Please confirm your understanding that we will not be in a position to
declare your Form
      S-1 effective until all outstanding comments regarding your Form 10-K for
the fiscal year
      ended December 31, 2021 have been resolved. In addition, to the extent
that any
      comments related to our review of your Form 10-K apply to disclosure in
the Form S-1,
      please make corresponding revisions to all affected disclosure.
        You may contact Robert Babula, Staff Accountant, at 202-551-3339 or Gus
Rodriguez,
Accounting Branch Chief, at 202-551-3752 if you have questions regarding
comments on the
financial statements and related matters. You may contact Ken Schuler, Mining
Engineer, at
202-551-3718 if you have questions regarding engineering comments. Please
contact Irene
Barberena-Meissner, Staff Attorney, at 202-551-6548 or Loan Lauren Nguyen,
Legal Branch
Chief, at 202-551-3642 with any other questions.



                                                            Sincerely,
FirstName LastNameRandall W. Atkins
                                                            Division of
Corporation Finance
Comapany NameRamaco Resources, Inc.
                                                            Office of Energy &
Transportation
October 31, 2022 Page 3
cc:       Matthew R. Pacey, P.C.
FirstName LastName