Mail Stop 4628
                                                           April 12, 2018

Via E-Mail
Juan Pablo Tardio
Chief Financial Officer
Helmerich & Payne, Inc.
1437 S. Boulder Ave., Suite 1400
Tulsa, Oklahoma 74119

       Re:    Helmerich & Payne, Inc.
              Form 10-K for Fiscal Year Ended September 30, 2017
              Response Dated March 15, 2018
              File No. 001-04221

Dear Mr. Tardio:

       We have reviewed your March 15, 2018 response to our comment letter 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 to these comments, we may have additional
comments.
Unless we note otherwise, our references to prior comments are to comments in
our March 6,
2018 letter.

Form 10-K for Fiscal Year Ended September 30, 2017

Notes to Consolidated Financial Statements, page 54

Note 1   Summary of Significant Accounting Policies, page 54

Valuation of Long-Lived Assets, page 56

1.     We note from your response to prior comment 1 that you have ten asset
groups. Using
       the rig information in Item 2   Properties of your Form 10-K, provide us
with a summary
       of your rigs by asset group. Include a description of the
characteristics supporting your
       asset groupings and list their respective geographic locations (e.g., by
state and / or
       country) and contract status. Also, describe your conclusion regarding
the
       interdependency of cash flows to the extent that you have rigs in the
same asset group
 Juan Pablo Tardio
Helmerich & Payne, Inc.
April 12, 2018
Page 2

       that are located in different countries or where there are factors that
may influence
       transfer decisions.

2.     For each respective asset group, provide us with a summary of your
future expectations
       for rig utilization levels, dayrates, and rig margins along with a
comparison of the key
       elements of your forecast to your historical experience with similar
market conditions.

3.     You indicate in your response to prior comment 1 that Domestic FlexRig4
and
       International FlexRig4 asset groups were subject to an impairment
recoverability test
       during the fiscal quarter ended September 30, 2017, while the remaining
eight asset
       groups were determined to not have impairment indicators during the
period. Explain the
       changes that occurred during the period and describe differences in
circumstances that
       resulted in the existence of impairment indicators for the Domestic and
International
       FlexRig4 asset groups compared to the other asset groups. See FASB ASC
360-10-35-21.

4.     To the extent that you have rigs that have remained idle for an extended
period or rigs
       that cannot be upgraded, specify such rigs and the asset groups to which
they belong. In
       addition, provide us with an analysis supporting your conclusion that
these rigs did not
       need to be tested for recoverability during the fiscal year ended
September 30, 2017.

5.     For the asset groups that were subject to an impairment recoverability
test, explain to us
       how you have considered providing expanded disclosure under Critical
Accounting
       Policies and Estimates to:

           State the percentage or amount by which the undiscounted cash flows
exceeded their
           respective carrying values as of the date of the impairment test;

           Discuss qualitative and quantitative information addressing the
uncertainty in the key
           assumptions underlying your impairment assessment (i.e., rig
utilization levels,
           dayrates, etc.); and,
           Address the effect of reasonably likely changes to these
assumptions.

       See Section V of SEC Release No. 33-8350.

       You may contact Jeannette Wong, Staff Accountant, at (202) 551-2137 or
Kimberly
Calder, Assistant Chief Accountant, at (202) 551-3701 with any questions.


                                                             Sincerely,

                                                             /s/ Ethan Horowitz

                                                             Ethan Horowitz
                                                             Accounting Branch
Chief
                                                             Office of Natural
Resources