December 17, 2018

Allen W. West
Chief Financial Officer
P.A.M. Transporation Services, Inc.
297 West Henri de Tonti Blvd
Tontitown, Arkansas 72770

       Re: P.A.M. Transporation Services, Inc.
           Form 10-K for the Year Ended December 31, 2017
           Form 10-Q for the Quarter Ended September 30, 2018
           File No. 000-15057

Dear Mr. West:

       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-Q for the Quarter Ended September 30, 2018

Financial Statements
Notes to Condensed Consolidated Financial Statements (unaudited)
Note C: Revenue Recognition, page 10

1.    Please disclose the amount by which each financial statement line item is
affected in
      the current reporting period by ASC 606 as compared with the guidance
that was in
      effect before the change in accordance with ASC 606-10-65-1(i), including
an explanation
      of the reasons for the significant changes identified.
2.    We note from disclosures provided elsewhere in your filing that your
operations can
      generally be classified into truckload services or brokerage and
logistics services.
      Truckload services include those transportation services for the pickup
and delivery of
      freight, and brokerage and logistics services consist of transportation
scheduling, routing,
      mode selection, transloading and other value added services related to
the transportation
      of freight. Please revise your revenue footnote to disclose whether the
services included in
 Allen W. West
P.A.M. Transporation Services, Inc.
December 17, 2018
Page 2
         your contracts with customers represent one or more performance
obligations.
         Additionally, we note revenue is generated and your customer receives
benefit as the
         freight progresses toward delivery locations. In this regard, please
explain why
         recognition of revenue at a point in time (i.e. upon completion of
delivery to the receiver's
         location) rather than over time is appropriate. As part of your
response, please tell us your
         consideration of the guidance outlined in ASC 606-10-25-27 and ASC
606-10-55-5 and 6
         in determining your accounting treatment.

         With respect to your brokerage and logistics services, please tell us
and revise your notes
         to disclose when performance obligation(s) are typically satisfied. If
over time, please
         disclose the method(s) used to recognize revenue and an explanation of
why the methods
         used provide a faithful depiction of the transfer of goods or
services.
Note F: Segment Information, page 13

3.       We note that you have two operating segments, Truckload Services and
Brokerage
         and Logistics Services, and that you have determined that these two
operating segments
         can be aggregated into a single reportable segment. Please compare and
contrast your
         operating segments relative to the areas listed in ASC 280-10-50-11a
through e.
         Regarding any differences among your operating segments, tell us why
you determined
         that disaggregation was not warranted. As part of your response,
please provide us with
         your historical and projected revenues, operating margin and measure
of segment
         profitability.
4.       Please revise your notes to the financial statements to comply with
the disclosure required
         by ASC 280-10-50-21a. Additionally, please provide the entity-wide
information required
         by ASC 280-10-50-38 to 42 or tell us why you believe the disclosure
are not required. In
         this regard, we note that you derive revenues from Mexico, Canada and
the United States.
       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 Heather Clark at 202-551-3624 or Jean Yu at 202-551-3305
with any
questions.



FirstName LastNameAllen W. West                                Sincerely,
Comapany NameP.A.M. Transporation Services, Inc.
                                                               Division of
Corporation Finance
December 17, 2018 Page 2                                       Office of
Transportation and Leisure
FirstName LastName