United States securities and exchange commission logo
January 18, 2022
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 November 30, 2021 response to our comment
letter 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.
Unless we note otherwise, our references to prior comments are to
comments in our October 29,
2021 letter.
Form 10-K for the Fiscal Year Ended December 31, 2020
Response Letter Dated November 30, 2021
1. We note from your
response to prior comment 2 that there are various interrelated factors
that could impact the
demand for, and prices of, crude oil, natural gas and NGLs. In view
of this, it appears
that you should provide more detailed disclosure describing the risks
specifically associated
with developments regarding climate change. For example, your
existing disclosure
makes reference to energy conservation measures, alternative fuel
requirements and
climate change-related initiatives, but does not appear to fully explain
the indirect
consequences of these types of business trends in the context of your
particular facts and
circumstances.
Timothy K. Driggers
EOG Resources, Inc.
January 18, 2022
Page 2
2. Your response to prior comment 2 states that as a result of
reputational risks from the
exploration for, and production of, crude oil, natural gas and NGLs,
you could experience
an increased cost of capital. However, it does not appear that risk
factor disclosure in your
Form 10-K explains how these types of reputational risks could expose
you to potential
adverse consequences related to your ability to obtain needed
financing on satisfactory
terms. Revise your disclosure accordingly.
3. We note the discussion in your response to prior comment 5 regarding
transition risks
related to climate change. Please expand your existing disclosure to
specifically describe
transition risks such as technological advances in energy storage and
power generation
and more directly explain how alternative energy sources could affect
the behavior of your
customers (e.g., due to the use of hybrid or electric vehicles). In
addition,
provide disclosure explaining how perceptions of the oil and gas
industry could affect
your ability to successfully implement the business strategy described
in your Form 10-K.
4. Your response to prior comment 6 states that expenditures associated
with compliance
activities related to safety and environmental regulations (including
climate-related laws
and regulations that are currently applicable to your business and
operations) are included
in Lease and Well expense or in General and Administrative
expense within your
consolidated income statements. Describe for us in greater detail how
you were able to
conclude the amounts incurred were not material and your consideration
of the disclosure
requirement per Item 101(c)(2)(i) of Regulation S-K.
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 the
comments.
FirstName LastNameTimothy K. Driggers Sincerely,
Comapany NameEOG Resources, Inc.
Division of
Corporation Finance
January 18, 2022 Page 2 Office of Energy
& Transportation
FirstName LastName