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                             August 1, 2023

       Lawrence Martin
       Chief Financial Officer
       Hallador Energy Company
       1183 East Canvasback Drive
       Terre Haute, Indiana 47802

                                                        Re: Hallador Energy
Company
                                                            Form 10-K for the
Fiscal Year ended December 31, 2022
                                                            Filed March 16,
2023
                                                            File No. 001-34743

       Dear Lawrence Martin:

              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 to these comments, we may have additional comments.

       Form 10-K for the Fiscal Year ended December 31, 2022

       Mining Properties, page 31

   1.                                                   We note that you have
not provided various disclosures that are required by Item 101 and
                                                        Item 102 of Regulation
S-K under the Business heading on page 4, and the Properties
                                                        heading on page 29,
though have referred to Management's Discussion and Analysis for a
                                                        discussion of these
topics. However, the disclosures you provide on pages 30-42 do not
                                                        appear to address all
of the requirements pertaining to these sections of Form 10-K, which
                                                        include Subpart 1300 of
Regulation S-K, applicable via Instruction 3 to Item 102.

                                                        We expect that you will
need to file an amendment to your annual report to resolve the
                                                        concerns raised in the
comments in this letter, regarding your business and mineral
                                                        property disclosures,
and will need to obtain and file an amendment to the Technical
                                                        Report Summary to
support your disclosures of mineral resources and reserves.
 Lawrence Martin
FirstName  LastNameLawrence Martin
Hallador Energy Company
Comapany
August     NameHallador Energy Company
       1, 2023
August
Page 2 1, 2023 Page 2
FirstName LastName
         For example, Item 1303 of Regulation S-K describes the content
required as summary
         disclosure pertaining to your mining properties, which should include
a map that shows
         the locations of all of your mining properties, as indicated in Item
1303(b)(1), and the
         overview information outlined in Item 1303(b)(2). The summary
disclosure should
         encompass all of your properties, including both material and
non-material properties, and
         should appear in advance of and incremental to the individual property
disclosures that are
         required by Item 1304 of Regulation S-K. The information required for
the individual
         property disclosure are more extensive and detailed in comparison.

         Please expand your disclosures to include and to differentiate between
the summary and
         individual property disclosures to comply with the aforementioned
guidance. Please
         position or reposition disclosures that are intended to be responsive
to these requirements
         to a dedicated section of your filing, such as the Properties section
on page 29, and
         similarly address the requirements of Item 101 of Regulation S-K.
2.       Please expand your disclosures of the mineral reserve estimate to
include the mineral
         price, cut-off grade, and metallurgical recovery factors utilized in
preparing the estimate
         as required by Item 1304(d)(1) of Regulation S-K.
3.       Please expand your disclosures to include a comparison of your mineral
reserves as of the
         end of the most recent fiscal year and the end of the preceding fiscal
year; this would
         generally entail a narrative having quantification of and an
explanation for the net
         difference, to comply with Item 1304(e) of Regulation S-K.
4.       The disclosures of mineralization under Other Properties on page 35,
including the 1.0
         million controlled saleable tons for the Ace in the Hole Mine #2, 0.3
million tons of low
         sulfur coal at Prosperity, and 1.7 million tons of salable coal with
an additional 0.6 million
         available at Freelandville, do not include details that would
ordinarily serve to clarify how
         the estimates are consistent with the definitions in Item 1300 of
Regulation S-K.

         Only estimates prepared by a qualified person meeting the definitions
in Item 1300 of
         Regulation S-K should be disclosed. If you believe this criteria would
apply, expand your
         disclosures to address the applicable requirements in Item 1303(b)(3)
of Regulation S-
         K or if this criteria has not been met, these estimates should be
removed.
5.       Please expand your disclosures to include the information required
under Item 1305 of
         Regulation S-K, regarding internal controls used in your exploration
and mineral resource
         and reserve estimation efforts.
Exhibits and Financial Statement Schedules, page 72

6.       We note that you filed a Technical Report Summary for the Oaktown
Mining Complex
         with your 2021 annual report though have not identified an updated
report or listed this
         report in your exhibit index for the 2022 annual report.
 Lawrence Martin
Hallador Energy Company
August 1, 2023
Page 3
         If you intend to rely upon this Technical Report Summary as support
for your mineral
         property disclosures that include estimates of resources or reserves,
this should be
         identified in your list of exhibits. However, under these
circumstances it appears that you
         will need to obtain and file an amendment to the Technical Report
Summary that includes
         additional information, as outlined in the remaining comments in this
letter.
7.       The Technical Report Summary referenced in the preceding comment does
not include all
         of the content prescribed by Item 601(b)(96) of Regulation S-K and
would therefore not
         adequately support your disclosures of mineral reserves and resources.
Please consult with
         the qualified person involved in preparing that report to obtain and
file a revised Technical
         Report Summary that includes all of the following information:

                A detailed description of the commodity price and cut-off grade
used, or minimum
              quality specifications where applicable, as referenced in Item
              601(b)(96)(iii)(B)(12)(iii);
                The commodity price projections indicated by Item
601(b)(96)(iii)(B)(16)(i);
                The information pertaining to environmental compliance,
permitting, and local
              individuals or groups outlined in Item 601(b)(96)(iii)(B)(17);
                The capital and operating costs, having major components set
out in tabular form,
              along with the associated level of accuracy as required by Item
601(b)(96)(iii)(18)(i);
                The tax assumptions with the net present value presented on an
after tax basis
              pursuant to Item (601)(b)(96)(iii)(B)(19)(i).
8.       The life-of-mine plan and project economics described in the Technical
Report Summary
         referenced above appear to include materials that have not been
classified as a mineral
         reserve. However, a prefeasibility study or feasibility study that is
used to establish the
         economic viability of reserves, as referenced in Item 1302(e)(3) of
Regulation S-K,
         should be based solely on materials that qualify as mineral reserves.

         Please arrange to obtain and file a revised Technical Report Summary
having a life-of-
         mine plan and project economics that are consistent with these
requirements.
        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 John Coleman, Mining Engineer, at 202-551-3610 or Karl
Hiller,
Branch Chief, at 202-551-3686 if you have questions regarding the comments.



FirstName LastNameLawrence Martin                              Sincerely,
Comapany NameHallador Energy Company
                                                               Division of
Corporation Finance
August 1, 2023 Page 3                                          Office of Energy
& Transportation
FirstName LastName