United States securities and exchange commission logo
September 9, 2021
Timothy K. Driggers
Chief Financial Officer
EOG Resources, Inc.
1111 Bagby
Sky Lobby 2
Houston, TX 77002
Re: EOG Resources, Inc.
Form 10-K for the
Fiscal Year Ended December 31, 2020
Filed February 25,
2021
File No. 001-09743
Dear Mr. Driggers:
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.
1. Your CSR report notes
that reducing emissions from your operations is important to EOG
for environmental,
operational, and economic reasons. We also note that you provided
more expansive
disclosure in your CSR report than you provided in your SEC filings.
Please advise us what
consideration you gave to providing the same type of climate-
related disclosure in
your SEC filings as you provided in your CSR report.
2. We note that you
generally refer to capital expenditures for climate-related projects. If
material, please
quantify these expenditures.
3. To the extent material,
discuss the indirect consequences of climate-related regulation or
business trends, such
as the following:
increased demand
for goods that result in lower emissions than competing products;
increased
competition to develop innovative new products that result in lower
emissions;
increased demand
for generation and transmission of energy from alternative energy
sources;
Timothy K. Driggers
EOG Resources, Inc.
September 9, 2021
Page 2
decreased demand for services related to carbon-based energy
sources; and
any anticipated reputational risks resulting from operations or
products that produce
material greenhouse gas emissions.
4. Quantify any material weather-related damages to your property or
operations.
5. If material, disclose any weather-related impacts on the cost or
availability of insurance.
6. Disclose the material effects of transition risks related to climate
change that may affect
your business, financial condition, and results of operations, such as
market trends that
may alter business opportunities, credit risks, or technological
changes.
7. Quantify any material increased compliance costs related to climate
change.
8. If applicable and material, provide disclosure about any purchase or
sale of carbon credits
or offsets and any material effects on your business, financial
condition, and results of
operations.
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 Wei Lu, Staff Accountant at (202) 551-3725 or Ethan
Horowitz,
Accounting Branch Chief at (202) 551-3311, if you have questions regarding
comments.
FirstName LastNameTimothy K. Driggers Sincerely,
Comapany NameEOG Resources, Inc.
Division of
Corporation Finance
September 9, 2021 Page 2 Office of
Energy & Transportation
FirstName LastName