Mail Stop 3030

                                                                   August 21,
2018

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

            Re:     Arcosa, Inc.
                    Amendment No.2 to Registration Statement on Form 10-12B
                    Filed August 1, 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

     Risk Factors, page 18

     1.     Please add a risk factor to discuss the exclusive forum provision
in each of your restated
            certificate of incorporation and bylaws, including an explanation
that such provisions
            may limit a shareholder's ability to bring a claim in a judicial
forum that it finds favorable
            for such disputes and may discourage lawsuits with respect to such
claims.

     Exhibit 99, Arcosa Combined Financial Statements as of December 31, 2017

     Note 7. Goodwill, page F-15

     2.     We reference your response to comment 9. Please explain how you
treated the assets
            (including goodwill), liabilities and results of operations of the
Mexican operations being
 Antonio Carrillo
Arcosa, Inc.
August 21, 2018
Page 2

       retained by Trinity in presenting the separate financial statements of
Arcosa. In this
       regard, also address how you allocated the Energy Equipment Group
goodwill between
       the operations retained by Trinity and the businesses of Arcosa.

3.     If you have excluded the cash flows and net assets, including goodwill,
of the Mexican
       operations being retained by Trinity from the separate financial
statements of Arcosa
       please explain to us the reason for the goodwill impairment in fiscal
2015.

       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