SEC Comment Letter for EQT Corp (EQT) (CIK 0000033213) (EQT) — Apr 16, 2018
EQT Corp (EQT) (CIK 0000033213)
Date: April 16, 2018 · CIK: 0000033213 · Accession: 0000000000-18-011472
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-03551
Letter
Mail Stop 4628 April 16, 2018 Via E -mail Robert J. McNally Chief Financial Officer EQT Corporation 625 Liberty Avenue, Suite 1700 Pittsburgh, Pennsylvania 15222
Re: EQT Corporation Form 10 -K for Fiscal Year Ended December 31, 2017 Filed February 1 5, 201 8 File No. 001-03551
Dear Mr. McNally :
We have reviewed your filing an d 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 busine ss days by providing the requested information or advis e 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 Fiscal Year Ended December 31, 2017
Consolidated Financial Statements, page 71
Notes to Consolidated Financial Statements, page 77
Note 23. Natural Gas Producing Activities (Unaudited), page 125
1. We note the line item “Extensions, discoveries and other additions” in your presentation of ch anges in net quantities of proved reserves. Tell us the nature and amount of other additions for each of the three years presented.
2. The amount of change attributable to the line item “Extensions, discoveries and other additions” in your presentation of changes in net quantities of proved reserves appears to
Robert J. McNally EQT Corporation April 16, 2018 Page 2
have been significant for each of the three years presented. However, the acco mpanying discussion of this line item does not provide any detail beyond that contained in the line item caption. Expand your disclosure to provide an appropriately detailed explanation of the nature and amount of the items underlying this line item for e ach period presented. See FASB ASC 932 -235-50-5.
3. You disclose that, d uring 2015, you revised your approach utilized to determine the gathering cost assumption within your determination of reserves , and that you believe the methodology that is currentl y utilized to determine the gathering rate reflects your current cash operating costs and gives consideration to your significant ownership interest in EQGP, EQM and RMP. Describe for us, in reasonable detail, both your current and prior approach to dete rmine gathering cost assumptions. Also, describe the specific differences between the two approaches, as well the reasons for the change in approach. As part of your response, explain how the current approach reflects your current cash operating costs an d gives consideration to your significant ownership interest in the identified entities.
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 Jeannette Wong, Staff Accountant , at (202) 551 -2137 or Brad Skinner, Senior Assistant Chief Accountant, at (202) 551 -3489 if you have questions regarding the engineering comments, or any other matters .
Sincerely,
/s/ Brad Skinner
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Mail Stop 4628 April 16, 2018 Via E -mail Robert J. McNally Chief Financial Officer EQT Corporation 625 Liberty Avenue, Suite 1700 Pittsburgh, Pennsylvania 15222 Re: EQT Corporation Form 10 -K for Fiscal Year Ended December 31, 2017 Filed February 1 5, 201 8 File No. 001-03551 Dear Mr. McNally : We have reviewed your filing an d 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 busine ss days by providing the requested information or advis e 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 Fiscal Year Ended December 31, 2017 Consolidated Financial Statements, page 71 Notes to Consolidated Financial Statements, page 77 Note 23. Natural Gas Producing Activities (Unaudited), page 125 1. We note the line item “Extensions, discoveries and other additions” in your presentation of ch anges in net quantities of proved reserves. Tell us the nature and amount of other additions for each of the three years presented. 2. The amount of change attributable to the line item “Extensions, discoveries and other additions” in your presentation of changes in net quantities of proved reserves appears to Robert J. McNally EQT Corporation April 16, 2018 Page 2 have been significant for each of the three years presented. However, the acco mpanying discussion of this line item does not provide any detail beyond that contained in the line item caption. Expand your disclosure to provide an appropriately detailed explanation of the nature and amount of the items underlying this line item for e ach period presented. See FASB ASC 932 -235-50-5. 3. You disclose that, d uring 2015, you revised your approach utilized to determine the gathering cost assumption within your determination of reserves , and that you believe the methodology that is currentl y utilized to determine the gathering rate reflects your current cash operating costs and gives consideration to your significant ownership interest in EQGP, EQM and RMP. Describe for us, in reasonable detail, both your current and prior approach to dete rmine gathering cost assumptions. Also, describe the specific differences between the two approaches, as well the reasons for the change in approach. As part of your response, explain how the current approach reflects your current cash operating costs an d gives consideration to your significant ownership interest in the identified entities. 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 Jeannette Wong, Staff Accountant , at (202) 551 -2137 or Brad Skinner, Senior Assistant Chief Accountant, at (202) 551 -3489 if you have questions regarding the engineering comments, or any other matters . Sincerely, /s/ Brad Skinner Brad Skinner Senior Assistant Chief Accountant Office of Natural Resources