Mail Stop 3030

                                                                  July 12, 2018

     Antonio Carrillo
     President and Chief Executive Officer
     Arcosa, Inc.
     2525 N. Stemmons Freeway
     Dallas, Texas 75207-2401

            Re:     Arcosa, Inc.
                    Amendment No. 1 to Registration Statement on Form 10-12B
                    Filed June 15, 2018
                    File No. 001-38494

     Dear Mr. Carrillo:

             We have reviewed your filing 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 these comments within ten business days by
providing the requested
     information or advise us as soon as possible when you will respond. If you
do not believe our
     comments apply to your facts and circumstances, please tell us why in your
response.

          After reviewing your response and any amendment you may file in
response to these
     comments, we may have additional comments.

     Exhibit 99.1

     Forward-Looking Statements, page 38; and
     Reasons for Furnishing this Information Statement, page 40

     1.     We note your disclosure in the last paragraphs on page 39 and page
40 that you undertake
            no obligation to update your disclosure. Revise to clarify that you
will update your
            disclosure if required by federal securities laws.

     Treatment of the Distribution, page 45

     2.     We note your reference to "certain stockholders" in the first
sentence of the last
            paragraph on page 46. Clarify which stockholders would have to
provide the information
            described relating to the distribution.
 Antonio Carrillo
Arcosa, Inc.
July 12, 2018
Page 2

Unaudited Pro Forma Combined Financial Statements, page 51

3.     Please revise to include the pro forma adjustments and resulting pro
forma balances
       required by Article 11 of Regulation S-X.

Management's Discussion and Analysis of Financial Condition and Results of
Operations

Results of Operations, page 66

4.     We note that you provide a discussion of results of operations for each
segment. Please
       revise to also provide a discussion of the consolidated results of
Arcosa for each period as
       required by Item 303(A) of Regulation S-K.

5.     When multiple factors are identified, please revise to discuss and
quantify the impact of
       each factor. For example, disclose the amount of revenue and expense
that the trench
       shoring products acquisition in the third quarter of 2017 contributed in
the construction
       products group on page 66 and the impact of improved pricing and
increased shipping
       volumes in the utility structures product line in the energy equipment
group on page 67.

Executive Officers, page 77

6.     Ensure that you have clearly disclosed all background information
required by
       Regulation S-K Item 401(e)(1), including the business experience of Mr.
Carrillo during
       the past five years, and the principal business of Mexichem S.A.B. Also,
indicate the
       periods Mr. Carrillo served on Trinity Industries' board.

Transition Services Agreement, page 105

7.     Please disclose the duration of the agreement.

The Separation and Distribution Agreement, page 103

8.     Please tell us whether the arbitration provision in this agreement would
have any impact
       on the rights of holders of Arcosa's shares under the federal securities
laws.

Arcosa Combined Financial Statements as of December 31, 2017

Note 7. Goodwill, page F-15

9.     We see that you reassessed goodwill in connection with the announced
spin-off and
       identified $89.5 million of impairment in the Energy Equipment Group as
of
       December 31, 2015. Since you state that Arcosa's reporting units are the
same as those
       used by Trinity for annual goodwill impairment testing, please disclose
the specific
 Antonio Carrillo
Arcosa, Inc.
July 12, 2018
Page 3

       circumstances that resulted in the impairment as a result of the
spin-off and explain to us
       why this was not recorded in an earlier period by Trinity.

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

       You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio,
Accounting
Branch Chief, at (202) 551-3676 if you have questions regarding comments on the
financial
statements and related matters. Please contact Tim Buchmiller at (202) 551-3635
or Daniel
Morris, Special Counsel, at (202) 551-3314 with any other questions.


                                                            Sincerely,

                                                            /s/ Daniel Morris
for

                                                            Amanda Ravitz
                                                            Assistant Director
                                                            Office of
Electronics and Machinery


cc:   Stephen F. Arcano, Esq.
      Skadden, Arps, Slate, Meagher & Flom LLP