March 31, 2005
Mail Stop 0305

Via U.S. Mail and Facsimile

Larry J. Goddard
Chief Financial Officer
P.A.M. Transportation Services, Inc.
297 West Henri De Tonti Blvd
P.O. Box 188
Tontitown, Arkansas 72770-0188

RE:	P.A.M. Transportation Services, Inc. (the "Company")
	Form 10-K for the fiscal year ended December 31, 2004
	File No. 0-15057

Dear Mr. Goddard:

Based upon an examination restricted solely to considerations of
the
Financial Statements, Management`s Discussion and Analysis, and
Selected Financial Data, the staff has the following comments on
the
above-referenced documents.  We think you should revise all future
filings in response to these comments.  If you disagree, we will
consider your explanation as to why our comments are inapplicable
or
a revision is unnecessary.  Please be as detailed as necessary in
your response.  In some of our comments, we may ask you to provide
us
with supplemental information so we may better understand your
disclosure.  After reviewing this information, we may or may not
raise additional comments.

Please understand that the purpose of our review process is to
assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing.  We look
forward to working with you in these respects.  We welcome any
questions you may have about our comments or on any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Please respond to confirm that such comments will be complied
with,
or, if certain of the comments are deemed inappropriate by the
Company, advise the staff of the reason thereof.

Pursuant to Rule 101(a)(3) of Regulation S-T, your response should
be
submitted in electronic form, under the label "corresp" with a
copy
to the staff.  Please respond within ten (10) business days.



Form 10-K for the fiscal year ended December 31, 2004

Item 6 - Selected Financial Data, page 11

1. Please note that in accordance with Item 301(b)(2) of
Regulation
S-K, you should describe (by footnote or otherwise) any factors
that
materially affect the comparability of information included in
selected financial data.  In this regard, we note that during
fiscal
2002 you received $54 million in proceeds from your sale of equity
securities in which you paid down a significant portion of your
long-
term debt and in fiscal 2003, you acquired the assets and
businesses
of East Coast Transport and McNeil Trucking, Inc.  To the extent,
these and other transactions are material to and affect the trends
of
your financial condition and results of operations, you should
consider revising future filings to briefly describe or cross-
reference to a discussion, thereof.

Item 7 - Management`s  Discussion and Analysis of Financial
Condition
and Results of Operations
Truckload Services, page 13
Logistics and Brokerage Services, page 15

2. We note from the discussion included in MD&A that the Company`s
operations involve both providing truckload freight serves and
providing brokerage and logistics services. We also note from the
discussion on page 12 that the Company believes it conducts its
operations in only one segment, the motor carrier segment.

Please explain in further detail why management believes that the
Company`s truckload freight and brokerage and logistics services
do
not represent separate reportable segments for which the
disclosures
outlined in SFAS No.131 should be provided. As part of your
response,
please explain in detail how the Company`s chief operating
decision
maker reviews and analyzes the Company`s operations for purposes
of
assessing performance and allocating resources. Also, if the
Company
does believe that these operations are separate segments, but that
they meet the criteria for aggregation outlined in paragraph 17 of
SFAS No.131, please explain in detail the basis for this
conclusion.

In the event that these operations do not meet the requirements
outlined in SFAS No.131 for presentation as separate segments,
please
revise the notes to the Company`s financial statements to disclose
the amount of revenues attributable to the Company`s truckload
freight and brokerage and logistics services. Refer to the
requirements of paragraph 37 of SFAS No.131.


Note 1 - Accounting Policies
- Revenue Recognition, page 36

3. We note your revenue recognition policy for freight in transit
at
the end of a reporting period.  According to your disclosure, you
recognize revenue equal to the percentage of relative transit
miles
completed to the estimated total transit miles.  Further, it also
appears that you estimate and recognize the related expenses in
proportion to the freight revenue recognized.  Please tell us
supplementally why you believe your expense recognition policy
complies with the methods prescribed in EITF No. 91-9 which
provides
that freight expenses should be recognized as incurred.  If you
believe your results would not be materially different if expenses
were recognized as incurred, a statement to this effect should be
included in the notes to your financial statements.

Note 2 - Accounts Receivable, page 38

4. Please tell us and clarify in Note 2 why the analysis of
activity
in your allowance for doubtful accounts does not include a
$635,000
reduction to bad debt expense resulting from the settlement of the
lawsuit.

Commodity Price Risk, page 26
Note 16 - Derivatives and Hedging Activities, page 49

5. Please tell us and explain in further detail in the notes to
your
financial statements how you value and account for the heating oil
price derivatives discussed on pages 26 and 27 and in Note 16 to
your
financial statements. As part of your response and your revised
disclosure, please explain how you determined the fair value of
such
arrangements at both December 31, 2003 and 2004 and explain why
you
reflect changes in the fair values of such arrangements as
adjustments to "operating supplies expense" in your consolidated
statements of operations. If this treatment is used because you
believe the arrangements serve as hedges of your diesel fuel
purchases, explain in detail your basis for this conclusion. We
may
have further comment upon receipt of your response.

Note 18 - Acquisitions, page 50

6. In future filings, please revise to discuss the factors that
contributed to purchase prices that resulted in recognition of
goodwill with respect to your acquisitions of East Coast
transport,
Inc. and McNeill Trucking Inc. Additionally, please include
condensed
balance sheets disclosing the amounts assigned to the major
categories of assets and liabilities of the acquired entities at
the
acquisition dates. Refer to the requirements of paragraph 51c and
51e
of SFAS No.141. Also, please tell us why no identifiable
intangibles
other than non-compete agreements were recognized in connection
with
these acquisitions. We may have further comment upon receipt of
your
response.

Other

We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filing reviewed by the staff to be
certain
that they have provided all information investors require for an
informed decision.  Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filing or in response to
our comments on your filing.

* * * * *


You may contact Jean Yu at (202) 824-5421 or Linda Cvrkel, Branch
Chief, at (202) 942-1936 if you have questions regarding comments
on
the financial statements and related matters.

								Sincerely,


								Linda Cvrkel
								Branch Chief
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Larry J. Goddard
P.A.M. Transportation Services, Inc.
March 31, 2005
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