Mail Stop 4628
                                                            March 6, 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
              Filed November 22, 2017
              File No. 001-04221

Dear Mr. Tardio:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 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.     You disclose on page 11 that you assessed your idle drilling rigs as of
September 30,
       2017 and determined no additional impairment charges were necessary.
Describe, in
       reasonable detail, the methodologies, estimates and assumptions
underlying your
       assessment, including the extent to which assets were grouped and the
basis for any such
       grouping. As part of your response, explain how your assessment took
into consideration
       factors such as historical and future expectations for rig utilization
levels and rig fleet
       status, the continued decline in your backlog and increase in the
percentage of such
       backlog not reasonably expected to be filled. In this regard, we note
that your investor
 Juan Pablo Tardio
Helmerich & Payne, Inc.
March 6, 2018
Page 2

       presentation dated October 4, 2017 indicated that 55% of available rigs
were contracted
       as of October 4, 2017 and that in your International Land Operations, 22
of 38 rigs were
       idle as of October 4, 2017. See FASB ASC paragraphs 360-10-35-23 and
360-10-35-29
       through 360-10-35-35.

        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 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