July 11, 2019

J.C. Butler, Jr.
President and Chief Executive Officer
NACCO Industries, Inc.
5875 Landerbrook Drive
Suite 220
Cleveland, OH 44124-4069

       Re: NACCO Industries, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 6, 2019
           File No. 001-09172

Dear Mr. Butler:

       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 the Fiscal Year Ended December 31, 2018 Filed March 6, 2019

Item 1. Business, page 1

1.    We note footnote (e) to your reserve table on page 5 stating that
reserves are owned and
      controlled by the customer and, therefore, have not been listed in the
table. The
      provisions in Industry Guide 7 are applicable to mines, plants and other
significant
      properties owned or operated, or presently intended to be owned or
operated. See
      paragraph (b) of Industry Guide 7. Considering you operate these
properties please revise
      to include mineral reserve information for all properties in which you
own or operate or
      tell us why you do not believe it necessary to do so.
2.    Please disclose the coal price used to establish the economic viability
of the materials
      designated as mineral reserves.
3.    Please provide a general overview of the property, plant and equipment
included in your
 J.C. Butler, Jr.
NACCO Industries, Inc.
July 11, 2019
Page 2
       table on page 12 of your filing. To the extent coal or other processing
plants are included
       in the table include the capacity and utilization pursuant to the
Instructions to Item 102 of
       Regulation S-K.
       In closing, 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 Robert Shapiro, Staff Accountant, at (202) 551-3273 or
Robert S.
Littlepage, Accounting Branch Chief, at (202) 551-3361 with any questions. If
you have
questions regarding the mining industry disclosures, please contact John
Coleman, Mining
Engineer, at (202) 551-3610.



                                                              Sincerely,
FirstName LastNameJ.C. Butler, Jr.
                                                           Division of
Corporation Finance
Comapany NameNACCO Industries, Inc.
                                                           Office of
Telecommunications
July 11, 2019 Page 2
cc:       Elizabeth Loveman, Vice President and Controller
FirstName LastName