May 30, 2019

James O. Harp, Jr.
Executive Vice President and Chief Financial Officer
Hornbeck Offshore Services, Inc.
103 Northpark Boulevard
Covington, Louisiana 70433

       Re: Hornbeck Offshore Services, Inc.
           Form 10-K for the Year Ended December 31, 2018
           Filed February 28, 2019
           File No. 001-32108

Dear Mr. Harp:

       We have reviewed your filing 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 year ended December 31, 2018

Item 6 - Selected Financial Data
Non-GAAP Financial Measures, page 28

1.    In the reconciliation of EBITDA to GAAP on page 29, please revise the
reconciliation to
      begin with the GAAP measure for equal or greater prominence of the GAAP
measure
      pursuant to Question 102.10 of the staff's Compliance and Disclosure
Interpretations
      "Non-GAAP Financial Measures."
Critical Accounting Estimates
Carrying Value of Vessels, page 34

2.    You group vessels for impairment testing based on the operating and
marketing
      characteristics desired by your customers and these asset groups have
been defined as
      New Generation OSVs and MPSV's. Please tell us why grouping the OSV class
of
      vessels as a single asset group rather than separate asset groups for
each series is
 James O. Harp, Jr.
FirstNameOffshore Services, Inc.
Hornbeck LastNameJames O. Harp, Jr.
Comapany NameHornbeck Offshore Services, Inc.
May 30, 2019
Page 2
May 30, 2019 Page 2
FirstName LastName
         appropriate pursuant to ASC 360-10-35-23. Further, explain to us why
your grouping is
         appropriate given at December 31, 2018 50% or greater of each series
other than the 300
         series are stacked and the series 300 vessels are all operational.
Additionally, tell us why
         stacked vessels are not a separate asset group that should be tested
for impairment
         separately from operational vessels.
3.       From your disclosures, we note the following:
           Since 2016 through May 31, 2019 a majority of the number of OSV
vessels have been
            stacked;
           You have operating losses in each of the last three fiscal years and
for the three
            months ended March 31, 2019;
           You have negative operating cash flows in each of the two fiscal
years and for the
            three months ended March 31, 2019; and
           The average OSV dayrate at year end steadily decreased since 2014
and further
            decreased at March 31, 2019.

         Given the preceding and the extended amount of time that a significant
number of your
         OSV vessels have been stacked, please explain to us the basis for your
conclusion that
         your stacked OSV vessels are not impaired at of December 31, 2018 or
March 31, 2019.
         Tell us and discuss the specific assumptions used in your estimates in
preparing the
         undiscounted future cash flows used in your determination, including
but not limited to
         stacked vessels assumptions, and current and historical market
dayrates and utilization
         rates, and why your assumptions are reasonable under the
circumstances. Include how
         your estimate of the length of time it takes for the market to absorb
your stacked vessels as
         disclosed on page 34 of the 2018 Form 10-K has been factored into your
assumptions and
         conclusion. Additionally, tell us the aggregate carrying and fair
values for each series of
         OSV vessels at each of December 31, 2018 and March 31, 2019.
4.       We note reference on page 34 to Note 6 of the Financial Statements for
a further
         discussion of stacked vessels; however, it does not appear that
disclosure has been
         provided in this note. Please advise.
        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.
 James O. Harp, Jr.
Hornbeck Offshore Services, Inc.
May 30, 2019
Page 3

       You may contact Theresa Brillant at 202-551-3307 or Doug Jones at
202-551-3309 if you
have questions regarding comments on the financial statements and related
matters.



FirstName LastNameJames O. Harp, Jr.                    Sincerely,
Comapany NameHornbeck Offshore Services, Inc.
                                                        Division of Corporation
Finance
May 30, 2019 Page 3                                     Office of
Transportation and Leisure
FirstName LastName