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July 13, 2022
Herbert S. Vogel
President and Chief Executive Officer
SM Energy Company
1775 Sherman Street, Suite 1200
Denver, CO 80203
Re:SM Energy Company
Form 10-K for Fiscal Year Ended December 31, 2021
Filed February 25, 2022
Form 8-K, Filed February 24, 2022
File No. 001-31539
Dear Mr. Vogel:
            We have limited our review of your filings to the financial statements and related
disclosures 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 Fiscal Year Ended December 31, 2021
Business and Properties
Reserves
Proved Undeveloped Reserves, page 13
1.Please expand your discussion of the changes that occurred in your proved undeveloped
reserves relating to extensions, discoveries and infill development, and revisions of the
previous estimates to separately identify and quantify each material factor, including
offsetting factors, that contributed to the change to comply with Item 1203(b) of
Regulation S-K.

The disclosure of revisions in previous estimates of your proved undeveloped reserves
in particular should identify the changes associated with individual factors, such as
changes caused by commodity prices, costs, interest adjustments, well performance,

 FirstName LastNameHerbert S. Vogel
 Comapany NameSM Energy Company
 July 13, 2022 Page 2
 FirstName LastNameHerbert S. Vogel
SM Energy Company
July 13, 2022
Page 2
unsuccessful and/or uneconomic proved undeveloped locations.

Your disclosure should clearly identify the source of the change and include an
explanation relating to each of the items you identify. If two or more unrelated factors are
combined to arrive at the overall change for an item, please separately identify and
quantify each material factor so that the change in net reserve quantities between periods
is fully explained.
Notes to Consolidated Financial Statements
Supplemental Oil and Gas Information (Unaudited)
Standardized Measure of Discounted Future Net Cash Flows, page 99
2.Please expand the presentation of the standardized measure to clarify, if true, that future
cash flows take into account the estimated abandonment costs for the proved properties to
comply with FASB ASC 932-235-50-36.

If the abandonment costs, including such costs related to proved undeveloped locations,
have not been included for each of the periods presented, e.g. as of December 31, 2021,
2020 and 2019, please explain to us the rationale for excluding these costs from the
calculation of the standardized measure.
Form 8-K, Filed February 24, 2022
Exhibit 99.1
Adjusted Operating Margin Reconciliation, page 20
3.We note you identified Adjusted operating margin (before the effects of derivative
settlements) and Adjusted operating margin (including the effect of derivative settlements)
as non-GAAP measures and reconciled these measures to your oil, gas and NGL revenues
and also to income (loss) from operations for the three months ended December 31, 2021
and December 31, 2020.  Please tell us how you considered reconciling these measures to
the most directly comparable GAAP measure, fully-loaded GAAP gross margin.  Refer to
Item 10(e)(1)(i)(B) of Regulation S-K.
            In closing, 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.

 FirstName LastNameHerbert S. Vogel
 Comapany NameSM Energy Company
 July 13, 2022 Page 3
 FirstName LastName
Herbert S. Vogel
SM Energy Company
July 13, 2022
Page 3
             You may contact Sandra Wall, Petroleum Engineer, at (202) 551-4727, or John
Hodgin, Petroleum Engineer, at (202) 551-3699 on engineering matters.  Please contact Sondra
Snyder, Senior Staff Accountant, at (202) 551-3332 or Gus Rodriguez, Accounting Branch
Chief, at (202) 551-3752 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation