September 11, 2024

Philip Riley
Chief Financial Officer and Executive Vice President of Strategy
Riley Exploration Permian, Inc.
29 E. Reno Avenue, Suite 500
Oklahoma City, Oklahoma 73104

        Re: Riley Exploration Permian, Inc.
            Form 10-K for the Fiscal Year Ended December 31, 2023
            Filed March 6, 2024
            File No. 001-15555
Dear Philip Riley:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Annual Report for the fiscal year ended December 31, 2023
Business and Properties
Oil, Natural Gas and NGL Reserves
Proved Undeveloped Reserves (PUDs), page 10

1.      We note that the PUD conversion rates for the years ended December 31,
2022 and
        December 31, 2023 were substantially below the 20% rate implied by the
5 year rule.
        Describe for us the factors that impacted your conversion rates for
each of those years.
        As part of your response, provide us with a schedule that shows, for
each of the years
        ended December 2021, December 31, 2022 and December 31, 2023, the
development
        schedule underlying the disclosed proved undeveloped reserve volumes.
For each year
        end, the schedule should show the locations and volumes to be
developed, as well as the
        related capital expenditures, by year for each year in your adopted
five year development
        plan. Additionally, provide the actual PUD locations and volumes
developed, and related
        capital expenditures, for the years ended December 31, 2002 and
December 31, 2023 and
        year-to-date 2024.
2.      Disclosure under this section regarding changes to your PUD volumes
identifies various
 September 11, 2024
Page 2

       factors without indicating the quantity attributable to each factor.
Please expand the
       disclosure of the changes in the net quantities of proved undeveloped
reserves to include
       an explanation of the material changes related to each line item shown
in your
       reconciliation. To the extent that two or more unrelated factors are
combined to arrive at
       the line item figure, your disclosure should separately identify and
quantify each
       individual factor that contributed to a material change so that the
change in net reserves
       between periods is fully explained.

       The disclosure of revisions in the previous estimates of reserves should
identify such
       factors as changes caused by commodity prices, well performance,
unsuccessful and/or
       uneconomic proved undeveloped locations or the removal of proved
undeveloped
       locations due to changes in a previously adopted development plan. Refer
to Item 1203(b)
       of Regulation S-K.
Consolidated Financial Statements
Notes to the Consolidated Financial Statements
(15) Supplemental Oil and Gas Information (Unaudited)
Oil, Natural Gas and NGL Quantities, page F-37

3.     Your disclosure regarding changes in reserve quantities during the year
ended December
       31, 2023 indicates, in part, that you had downward revisions of 12.1
MMBoe which are
       primarily attributable to the removal of PUDs due to changes in your
development
       schedule. However, discussion of changes in your PUD volumes appearing
on page 10 of
       your filing indicates that downward revisions of your PUD volumes, due
to several
       different factors, were limited to 5.7 MMBoe. Revise the disclosure
related to revisions
       in previous estimates to separately identify and quantify each factor,
including offsetting
       factors, such that the change to the line item is fully explained. The
revised disclosure
       should indicate the extent to which changes were caused by economic
factors, such as
       costs and commodity prices, well performance, uneconomic proved
undeveloped
       locations, or the removal of proved undeveloped locations due to changes
in a previously
       adopted development plan. Refer to FASB ASC 932-235-50-5.
        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.

       Please contact Sandra Wall, Petroleum Engineer, at 202-551-4727 or Brad
Skinner,
Office Chief, at 202-551-3489 if you have questions regarding the engineering
comments.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Energy &
Transportation