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                            October 12, 2021

       Amanda M. Brock
       President and Chief Executive Officer
       Aris Water Solutions, Inc.
       9811 Katy Freeway, Suite 700
       Houston, Texas 77024

                                                        Re: Aris Water
Solutions, Inc.
                                                            Amendment No.1 to
Registration Statement on Form S-1
                                                            Filed October 7,
2021
                                                            File No. 333-259740
                                                            CORRESP filed
October 12, 2021

       Dear Ms. Brock:

               We have reviewed your amended registration statement and
supplemental
       correspondence 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 this letter by amending your registration
statement and providing the
       requested information. If you do not believe our comments apply to your
facts and
       circumstances or do not believe an amendment is appropriate, please tell
us why in your
       response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 6, 2021 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       Cover Page

   1.                                                   Please revise to
disclose the percentage of combined voting power of your common stock
                                                        that will be held by
your Existing Owners immediately after the offering.
       Organizational Structure, page 11

   2.                                                   Please reflect the
ownership of Class B common stock in the diagram reflecting your
                                                        ownership structure
immediately following the offering and related transactions.
 Amanda M. Brock
FirstName
Aris Water LastNameAmanda    M. Brock
           Solutions, Inc.
Comapany
October 12,NameAris
            2021      Water Solutions, Inc.
October
Page 2 12, 2021 Page 2
FirstName LastName
Note (a), page F-6

3.       Please reconcile the information regarding your pro forma cash
adjustment with the
         corresponding information under Use of Proceeds on page 60, with
regard to your
         acquisition of newly issued units and the distribution.
Note (b), page F-6

4.       We note that you are showing within your draft revisions to the pro
forma information, a
         pro-forma liability of $75.7 million associated with your Tax
Receivable Agreement.
         Please disclose the number of Solaris LLC Units that are assumed to be
redeemed by
         Existing Owners and any other material factors that were utilized in
your calculation of
         this adjustment. Given your disclosure on page 114, indicating you
expect payments
         under this agreement "will be substantial," may likewise cause a
"substantial negative
         impact" on your liquidity, will continue for more than 20 years, and
if there is a change of
         control or the agreement terminates early, that you would be required
to make a
         substantial, immediate lump-sum payment, further disclosure of key
provisions and
         reasonably likely effects should be made.

         For example, in considering the objective and disclosure requirements
outlined in FASB
         ASC 850-10-10 and 10-50, we believe that you should discuss the
circumstances under
         which conversion or termination may occur and would be reasonably
likely to occur,
         implications of either event for common shareholders (e.g., valuation
of interests and
         dividend payments), quantification of the liability that would arise
upon conversion and
         the payment that would be required if you experience a change of
control or if the
         agreeement terminates early, based on circumstances prevailing at the
end of the period
         covered by your report, also any material assumptions made in
compiling these figures
         and the reasonably possible range of effects that may occur if
differences between your
         assumptions and actual events or circumstances arise.

         Please include corresponding disclosures in the Prospectus Summary and
among the Risk
         Factors. Given your view of the payments that will be required under
the arrangement as
         substantial, similarly expand your disclosure in the Liquidity and
Capital Resources
         section of MD&A on page 73 to address the implications and reasonably
possible timing
         of events to comply with Item 303(a)(1) of Regulation S-K.
Unaudited Pro Forma Condensed Consolidated Financial Statements
Pro Forma Adjustments and Assumptions
Note (i), page F-7

5.       We note your disclosure that on a pro forma basis, basic earnings per
share and diluted
         earnings per share are the same as there were no antidilutive
securities during the periods
         presented. Please address each of the following issuance of
potentially dilutive securities
         with respect to their effect on 1) basic shares outstanding and 2)
diluted shares
         outstanding; for all periods presented:
 Amanda M. Brock
Aris Water Solutions, Inc.
October 12, 2021
Page 3

             632,353 shares of Class A common stock underlying restricted stock
units or other
           awards to be granted to certain employees and non-employee directors
pursuant to
           the 2021 Plan immediately after the closing of this offering; and
             Convertible securities including the 34,078,344 shares of Class A
common stock
           reserved for issuance upon exchange of the Solaris LLC Units as
disclosed on page
           22.

      Please clarify the nature of the restrictions associated with the
restricted stock units
      and specify if they are contingently returnable. Refer to ASC
260-10-45-12A.
      If you believe that potentially dilutive securities are antidilutive,
please clarify how this
      would apply to both the annual and interim pro forma periods if this is
your view.

Exhibits

6.    We note your response to prior comment 4. Please file your final form of
amended and
      restated certificate of incorporation as an exhibit to your registration
statement.
        You may contact Joseph Klinko, Staff Accountant, at 202-551-3824 or
John
Cannarella, Staff Accountant, at 202-551-3337 if you have questions regarding
comments on the
financial statements and related matters. Please contact Irene
Barberena-Meissner, Staff
Attorney, at 202-551-6548 or Laura Nicholson, Special Counsel, at 202-551-3584
with any other
questions.



                                                              Sincerely,
FirstName LastNameAmanda M. Brock
                                                              Division of
Corporation Finance
Comapany NameAris Water Solutions, Inc.
                                                              Office of Energy
& Transportation
October 12, 2021 Page 3
cc:       Hillary H. Holmes, Esq.
FirstName LastName