December 5, 2019

John T. Drexler
Chief Financial Officer
Arch Coal Inc.
One CityPlace Drive
Suite 300
St. Louis, MO 63141

       Re: Arch Coal Inc.
           Form 10-K for the Year Ended December 31, 2018
           Filed February 14, 2019
           Form 10-Q for the Quarter Ended September 30, 2019
           Filed October 22, 2019
           File No. 001-13105

Dear Mr. Drexler:

      We have reviewed your filings and have the following comment. In our
comment, we
may ask you to provide us with information so we may better understand your

       Please respond to this comment within ten business days by providing the
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your

       After reviewing your response to the comment, we may have additional

Form 10-Q for the Quarter Ended September 30, 2019

Item 1. Financial Statements
Note 5. Preference Rights Lease Application Settlement Income, page 10

1.    We note you recorded a $39 million gain related to a settlement with the
United States
      Department of Interior and as part of the settlement you will receive $67
million in the
      form of royalty credits on federal coal leases which will be used to
settle 50% of your
      monthly royalty obligations over 18-24 months beginning in September
2019. Please tell
      us how your treatment of this gain is consistent with ASC 450-30-25-1.
        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.
 John T. Drexler
Arch Coal Inc.
December 5, 2019
Page 2

        You may contact Myra Moosariparambil at (202) 551-3796 or Steve Lo at
(202) 551-
3394 if you have any questions.

FirstName LastNameJohn T. Drexler
                                                         Division of
Corporation Finance
Comapany NameArch Coal Inc.
                                                         Office of Energy &
December 5, 2019 Page 2
cc:       Rosemary Klein
FirstName LastName