SEC Comment Letter for EVERGY METRO, INC. (CIK 0000054476) — Sep 2, 2022
EVERGY METRO, INC. (CIK 0000054476)
Date: Sept. 2, 2022 · CIK: 0000054476 · Accession: 0000000000-22-009551
AI Filing Summary & Sentiment
File numbers found in text: 001-38515
Referenced dates: August 5, 2022
Letter
United States securities and exchange commission logo September 1, 2022 Kirkland B. Andrews Chief Financial Officer Evergy, Inc. 1200 Main Street Kansas City, Missouri 64105 Re:Evergy, Inc. Form 10-K for the Fiscal Year ended December 31, 2021 Filed February 25, 2022 Response Letter dated August 5, 2022 File No. 001-38515 Dear Mr. Andrews: We have reviewed your August 5, 2022 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 July 22, 2022 letter. Form 10-K for the Fiscal Year ended December 31, 2021 Management's Discussion and Analysis Executive Summary Non-GAAP Measures, page 38 1.We have read your response to prior comment one, including the incremental disclosures that you have proposed to include in future filings that include your non-GAAP utility margin. Please expand such disclosures to address the following additional points.
•Provide further details in footnote (a) to the reconciliation of the nature of operating and maintenance expenses that are deemed to be directly attributable to your revenue- producing activities (i.e. cost of sales), and to clarify how these are differentiated
FirstName LastNameKirkland B. Andrews Comapany NameEvergy, Inc. September 1, 2022 Page 2 FirstName LastName Kirkland B. Andrews Evergy, Inc. September 1, 2022 Page 2 from other costs reported in this line item on page 72.
•Provide quantification of the various factors underlying changes in the measures of GAAP gross margin in the narrative which follows the reconciliation, comparable to your discussion and analysis of changes in non-GAAP utility gross margin. You may contact Lily Dang at (202) 551-3867 or Mark Wojciechowski at (202) 551- 3759 if you have questions regarding comments on the financial statements and related matters. Please contact Karl Hiller - Branch Chief at (202) 551-3686 with any other questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation
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United States securities and exchange commission logo
September 1, 2022
Kirkland B. Andrews
Chief Financial Officer
Evergy, Inc.
1200 Main Street
Kansas City, Missouri 64105
Re:Evergy, Inc.
Form 10-K for the Fiscal Year ended December 31, 2021
Filed February 25, 2022
Response Letter dated August 5, 2022
File No. 001-38515
Dear Mr. Andrews:
We have reviewed your August 5, 2022 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
July 22, 2022 letter.
Form 10-K for the Fiscal Year ended December 31, 2021
Management's Discussion and Analysis
Executive Summary
Non-GAAP Measures, page 38
1.We have read your response to prior comment one, including the incremental disclosures
that you have proposed to include in future filings that include your non-GAAP utility
margin. Please expand such disclosures to address the following additional points.
•Provide further details in footnote (a) to the reconciliation of the nature of operating
and maintenance expenses that are deemed to be directly attributable to your revenue-
producing activities (i.e. cost of sales), and to clarify how these are differentiated
FirstName LastNameKirkland B. Andrews
Comapany NameEvergy, Inc.
September 1, 2022 Page 2
FirstName LastName
Kirkland B. Andrews
Evergy, Inc.
September 1, 2022
Page 2
from other costs reported in this line item on page 72.
•Provide quantification of the various factors underlying changes in the measures of
GAAP gross margin in the narrative which follows the reconciliation, comparable to
your discussion and analysis of changes in non-GAAP utility gross margin.
You may contact Lily Dang at (202) 551-3867 or Mark Wojciechowski at (202) 551-
3759 if you have questions regarding comments on the financial statements and related
matters. Please contact Karl Hiller - Branch Chief at (202) 551-3686 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation