Mail Stop 3030

                                                                 September 13,
2018

     Antonio Carrillo
     President and Chief Executive Officer
     Arcosa, Inc.
     2525 N. Stemmons Freeway
     Dallas, Texas 75207-2401

            Re:     Arcosa, Inc.
                    Amendment No. 3 to Registration Statement on Form 10-12B
                    Filed August 29, 2018
                    File No. 001-38494

     Dear Mr. Carrillo:

            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 and any amendment you may file in
response to these
     comments, we may have additional comments.

     Exhibit 99.1

     Arcosa Combined Financial Statements as of December 31, 2017

     Note 7. Goodwill, page F-15

     1.     We note your response to prior comment 2 and 3. Please revise to
include enhanced
            discussion, consistent with the response, that the impairment was
largely the result of a
            significant downturn in certain energy markets served by Arcosa in
2015 and that the
            impaired goodwill related to several acquisitions consummated in
2013 and 2014.
 Antonio Carrillo
Arcosa, Inc.
September 13, 2018
Page 2

       You may contact Kristin Lochhead at (202) 551-3664 or Brian Cascio,
Accounting
Branch Chief, at (202) 551-3676 if you have questions regarding comments on the
financial
statements and related matters. Please contact Tim Buchmiller at (202) 551-3635
or Daniel
Morris, Special Counsel, at (202) 551-3314 with any other questions.


                                                          Sincerely,

                                                          /s/ Daniel Morris for

                                                          Amanda Ravitz
                                                          Assistant Director
                                                          Office of Electronics
and Machinery


cc:   Stephen F. Arcano, Esq.
      Skadden, Arps, Slate, Meagher & Flom LLP