United States securities and exchange commission logo





                            November 2, 2021

       Harry N. Vafias
       Chief Executive Officer
       Imperial Petroleum Inc./Marshall Islands
       331 Kifissias Avenue
       Erithrea 14561 Athens, Greece

                                                        Re: Imperial Petroleum
Inc./Marshall Islands
                                                            Amendment No. 1 to
Draft Registration Statement on Form F-1
                                                            Submitted October
18, 2021
                                                            CIK 0001876581

       Dear Mr. Vafias:

             We have reviewed your amended draft registration statement 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

       Amendment No. 1 to Draft Registration Statement on Form F-1

       Management's Discussion and Analysis
       Results of Operataions, page 71

   1.                                                   We note that you have
experienced changes in the mix of your charter revenues including
                                                        a decrease in bareboat
activity and an increase in spot rate activity since 2019. Please
                                                        explain the underlying
factors that are causing the change in mix and clarify the impacts
                                                        this change has had on
your utilization rates and profitability. Please also describe how
                                                        management has
considered the change in mix as a known trend that is reasonably likely
                                                        to cause a material
change in the relationship between costs and revenues. Refer to Item
                                                        303(b)(2)(ii) of
Regulation S-K.
 Harry N. Vafias
Imperial Petroleum Inc./Marshall Islands
November 2, 2021
Page 2

        You may contact Brian McAllister, Staff Accountant, at 202-551-3341 or
Craig Arakawa,
Accounting Branch Chief, at 202-551-3650 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 LastNameHarry N. Vafias
                                                      Division of Corporation
Finance
Comapany NameImperial Petroleum Inc./Marshall Islands
                                                      Office of Energy &
Transportation
November 2, 2021 Page 2
cc:       Finn Murphy, Esq.
FirstName LastName