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CORRESP
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September 17, 2021

Securities and Exchange Commission

Division of Corporation Finance

100 F Street N.E.

Washington, D.C. 20549

Attn:  Mark Wojciechowski and Lily Dang, Staff Accountants

    Re:

    NRG Energy, Inc.

    Form 10-K for the Fiscal Year Ended December 31, 2020

    Filed March 1, 2021

    File No. 001-15891

Dear Mr. Wojciechowski and Ms. Dang:

This
letter sets forth the responses of NRG Energy, Inc. (the “Company”) to the comments provided by the Staff of the Securities
and Exchange Commission (the “Staff”) in its comment letter dated September 3, 2021 concerning the Company’s Form 10-K for
the Fiscal Year Ended December 31, 2020. We look forward to working with the Staff and improving the disclosures in our filings.

The Staff’s comments are repeated below in
bold for your convenience and the Company’s responses are as follows:

Form 10-K for the Fiscal Year Ended December 31, 2020

Management's Discussion and Analysis of Financial Condition
and Results of Operations

Consolidated Results of Operations for the years ended December 31,
2020 and 2019

Economic Gross Margin, page 53

1. We note that you identify “economic gross margin”
as a non-GAAP measure, and provide a reconciliation to “gross margin” on page 53 as the most directly comparable GAAP
measure.  You include a compilation of gross margin, which reflects various deductions from operating revenues to yield the measure
for each period.

However, the deductions for 2020 amount to
$5,139 which is not consistent with the cost of sales that you report on page 52 of $4,920, nor the cost of operations that you
report on page 92 of $6,540, and it appears that you have excluded depreciation and amortization from all three measures; the
corresponding 2019 amounts reflect similar discrepancies.

Please revise your compilation of gross
margin and the related disclosures on pages 55 and 56 as necessary to reflect all costs of sales that would be attributable to operating
revenues in accordance with GAAP, consistent with the reporting requirements in Rule 5-03.2 of Regulation S-X and the definition
of gross margin in the FASB Master Glossary.

If the cost of sales measure
reported on page 52 does not reflect all costs and expenses that would be attributable to revenues in accordance with GAAP, the
measure should be revised for completeness or relabeled to more clearly reflect its composition.

    1

In the Company’s Annual Report on Form 10-K for
the fiscal year ended December 31, 2020, the deductions from total operating revenues to calculate gross margin were Cost of fuel,
Purchased power and Other costs of sales, which aggregate to $4,920 million and were presented as Cost of sales on page 52, in addition
to Mark-to-market for economic hedge activities and Contract and emission credit amortization, which were shown separately on page 52.
In total, the deductions to calculate gross margin, which represented the costs applicable to total operating revenues, were $5,139 million
in 2020 as presented in the reconciliation of gross margin to economic gross margin on page 53. The Company will revise its presentation
on page 52 to show Cost of fuel, Purchased power and Other costs of sales as separate lines in lieu of the combined Cost of sales
to make the presentation consistent.

In
addition, the Company presented separately Operations and maintenance and Other cost of operations on page 52. Operations
and maintenance costs primarily consist of preventative and corrective maintenance activities to ensure the safe
and reliable operation of the Company’s generation portfolio, as well as costs
associated with retaining and maintaining the Company’s customer base, such as call center support, portfolio maintenance, and
data analytics. Other cost of operations primarily includes gross receipts taxes, insurance, property taxes and asset
retirement obligation expense. These costs are not included in the reconciliation of gross margin to economic gross margin on
page 53, as gross margin does not consider all operating costs, only the costs applicable to total operating revenues in
accordance with the definition of gross margin in the FASB Master Glossary. Along with the costs detailed in the paragraph above,
the aggregate Cost of operations that is presented on the Consolidated Statement of Operations on page 92 is $6,540
million.

While the Company presents Depreciation and amortization
separately from Cost of operations in its Consolidated Statement of Operations, in consideration of the guidance in SAB Topic 11:B, Regulation
S-X Rule 5-03.2, and the definition of gross margin in the FASB Master Glossary, the Company will revise its presentation of Gross
margin in MD&A on pages 53 through 56 to include Depreciation and amortization. Please see Attachment A for an illustrative presentation
of the primary changes to be made by the Company in future filings. The illustrative presentation reflects the application of the foregoing
proposed revisions to the financial data tables set forth on pages 52, 53 and 92 of the Company’s Annual Report on Form 10-K
for the fiscal year ended December 31, 2020.

 2. We note that you disaggregate your Cost of Operations
measure in MD&A to identify the components Cost of sales, Mark-to-market for economic hedging activities, Contract and emissions
credit amortization, Operations and maintenance, and Other cost of operations.

Given your presentation in the Statements of
Operations on page 92, tell us how Cost of Operations may be similar to Cost of Sales, and how you considered the guidance in SAB
Topic 11:B, as may be applied to your measure.  Please expand your disclosures in financial statement Note 2 to include a description
of the costs reported within Cost of Operations, including each of the subcategories identified in MD&A.

Please also conform the labeling of the line
caption on page 52 with that which appears on page 92, and provide some description of the measure as a subcategory of and
in relation to “Total operating costs and expenses.”

Cost of operations includes all cost associated with the
sales of goods and services to customers (Cost of fuel, Purchased power, Other costs of sales, Mark-to-market for economic hedge activities,
and Contract and emission credit amortization), as well as costs to maintain and operate the business as described above. In consideration
of the guidance in SAB Topic 11:B, the Company plans to revise MD&A as described above to incorporate Depreciation and amortization
into the calculation of gross margin.

    2

In response to the Staff’s comment, the Company will
expand its disclosures in Note 2 in future annual filings to include further description of the costs reported within Cost of operations,
including each of the subcategories identified in MD&A; Cost of fuel, Purchased power, Other cost of sales, Mark-to-market for economic
hedging activities, Contract and emission credit amortization, Operations and maintenance, and Other cost of operations. Please see Attachment
B for an illustrative disclosure to be used by the Company in future annual filings. The illustrative disclosure reflects the application
of the foregoing proposed revisions to Note 2 of our Annual Report on Form 10-K for the fiscal year ended December 31, 2020.

Additionally, in consideration of the guidance in SAB Topic
11:B, the Company will revise in future filings its line caption of Cost of operations on page 92 to Cost of operations (excluding
depreciation and amortization shown below) and will conform the labeling on page 52.

We hope that the foregoing has been responsive to your comments and
await the Staff’s response.  Please contact David Callen, Senior Vice President and Chief Accounting Officer, at (609) 524-4734,
Brian Curci, Executive Vice President and General Counsel, at (609) 524-5171, or me at (609) 524-5475 if you have questions regarding
our responses or related matters.

    Sincerely,

    /s/ Alberto
    Fornaro

    Alberto Fornaro

    Executive Vice President and

    Chief Financial Officer

    cc:

    Brian Curci, Esq., Executive Vice President and General Counsel,
    NRG Energy, Inc.

    David Callen, Senior Vice President and Chief Accounting Officer, NRG
    Energy, Inc.

    3

Attachment A

(Revisions are shown in blue)

Excerpt
of the Revised Consolidated Statements of Operations from the Annual Report on Form 10-K for the fiscal year ended
December 31, 2020 (page 92):

    For the Year Ended December 31,

    (In millions, except per share amounts)
    2020
    2019
    2018

    Operating Revenues

    Total operating revenues
    $ 9,093
    $ 9,821
    $ 9,478

    Operating Costs and Expenses

    Cost of operations (excluding Depreciation and amortization shown below)
      6,540
      7,303
      7,108

    Depreciation and amortization
      435
      373
      421

    Impairment losses
      75
      5
      99

    Selling, general and administrative costs
      933
      827
      799

    Reorganization costs
      -
      23
      90

    Development costs
      8
      7
      11

    Total operating costs and expenses
      7,991
      8,538
      8,528

    Gain on sale of assets
      3
      7
      32

    Operating Income
      1,105
      1,290
      982

    4

Excerpt
of the Revised Consolidated Results of Operations table from the MD&A Section of the Annual Report on Form 10-K
for the fiscal year ended December 31, 2020 (page 52):

    Year Ended December 31,

    (In millions, except otherwise noted)
    2020
    2019
    Change

    Operating Revenues

    Retail revenue
      7,460
      7,533
      (73 )

    Energy revenue(a)
      539
      1,169
      (630 )

    Capacity revenue(a)
      680
      700
      (20 )

    Mark-to-market for economic hedging activities
      95
      33
      62

    Other revenues(a)(b)
      319
      386
      (67 )

    Total operating revenues
      9,093
      9,821
      (728 )

    Operating Costs and Expenses

    Cost of fuel
      851
      1,080
      229

    Purchased power
      1,470
      2,181
      711

    Other cost of sales(c)
      2,599
      2,617
      18

    Mark-to-market for economic hedging activities
      214
      53
      (161 )

    Contract and emissions credit amortization(c)
      5
      19
      14

    Operations and maintenance
      1,129
      1,082
      (47 )

    Other cost of operations
      272
      271
      (1 )

    Cost of operations (excluding Depreciation and amortization shown below)
      6,540
      7,303
      763

    Depreciation and amortization
      435
      373
      (62 )

    Impairment losses
      75
      5
      (70 )

    Selling, general and administrative costs
      933
      827
      (106 )

    Reorganization costs
      -
      23
      23

    Development costs
      8
      7
      (1 )

    Total operating costs and expenses
      7,991
      8,538
      547

    Gain on sale of assets
      3
      7
      (4 )

    Operating Income
      1,105
      1,290
      (185 )

(a) Includes realized gains and losses from financially settled transactions

(b) Includes realized and unrealized trading gains and losses

(c) Includes amortization of SO2 and NOx credits and excludes amortization of RGGI credits

    5

Excerpt
of the Revised Reconciliation of Gross Margin to Economic Gross Margin from the MD&A Section of the Annual Report
on Form 10-K for the fiscal year ended December 31, 2020 (page 53):

Economic Gross Margin

In addition to gross margin, the Company evaluates
its operating performance using the measure of economic gross margin, which is not a GAAP measure and may not be comparable to other companies’
presentations or deemed more useful than the GAAP information provided elsewhere in this report. Economic gross margin should be viewed
as a supplement to and not a substitute for the Company's presentation of gross margin, which is the most directly comparable GAAP measure.
Economic gross margin is not intended to represent gross margin. The Company believes that economic gross margin is useful to investors
as it is a key operational measure reviewed by the Company's chief operating decision maker. Economic gross margin is defined as the sum
of energy revenue, capacity revenue and other revenue, less cost of fuel, purchased power and
other costs of sales. Economic gross margin does not include mark-to-market gains or losses on economic hedging activities, contract and
emissions credit amortization, or depreciation and amortization, operations and maintenance,
or other cost of operations operating costs.

The tables below present the composition and reconciliation
of gross margin and economic gross margin for the years ended December 31, 2020 and 2019 based on the Company's reportable segments:

    Year Ended December 31, 2020

    ($ in millions, except otherwise noted)
    Texas
    East
    West/Other
    Subtotal
    Corporate/
 Eliminations
    Total

    Retail revenue
    $ 6,061
    $ 1,401
    $ -
    $ 7,462
    $ (2 )
    $ 7,460

    Energy revenue
      24
      183
      333
      540
      (1 )
      539

    Capacity revenue
      -
      620
      61
      681
      (1 )
      680

    Mark-to-market for economic hedging activities
      2
      88
      (3 )
      87
      8
      95

    Contract amortization
      -
      -
      -
      -
      -
      -

    Other revenue
      222
      62
      43
      327
      (8 )
      319

    Total operating revenues
      6,309
      2,354
      434
      9,097
      (4 )
      9,093

    Cost of fuel
      (546 )
      (151 )
      (154 )
      (851 )
      -
      (851 )

    Purchased power
      (945 )
      (507 )
      (24 )
      (1,476 )
      6
      (1,470 )

    Other costs of sales(a)(b)(c)
      (2,165 )
      (422 )
      (12 )
      (2,599 )
      -
      (2,599 )

    Mark-to-market for economic hedging activities
      (211 )
      5
      -
      (206 )
      (8 )
      (214 )

    Contract and emission credit amortization
      (5 )
      -
      -
      (5 )
      -
      (5 )

    Depreciation and amortization
      (227 )
      (142 )
      (32 )
      (401 )
      (34 )
      (435 )

    Gross margin
    $ 2,210
    $ 1,137
    $ 212
    $ 3,559
    $ (40 )
    $ 3,519

    Less: Mark-to-market for economic hedging activities, net
      (209 )
      93
      (3 )
      (119 )
      -
      (119 )

    Less: Contract and emission credit amotization
      (5 )
      -
      -
      (5 )
      -
      (5 )

    Less: Depreciation and amotization
      (227 )
      (142 )
      (32 )
      (401 )
      (34 )
      (435 )

    Economic gross margin
    $ 2,651
    $ 1,186
    $ 247
    $ 4,084
    $ (6 )
    $ 4,078

(a) Includes capacity and emissions credits

(b) Includes $1,967 million and $10 million of TDSP expense in Texas and East, respectively

(c) Excludes depreciation and amortization shown separately

    6

Attachment B

(Revisions are shown in blue)

Excerpt
of the Revised Note 2, Summary of Significant Accounting Policies, to the Consolidated Financial Statements in the Annual
Report on Form 10-K for the fiscal year ended December 31, 2020 (page 100):

Contract and
Emission Credit Amortization

Assets and liabilities recognized
through acquisitions related to the purchase and sale of electric
capacity and energy and energy-related products in future periods for which
the fair value has been determined to be significantly less or more than market are amortized to operating
revenues or cost of operations over the term of each underlying contract based on actual generation and/or contracted volumes.

Emission
credits represents the right to generate a specified amount of emissions, including sulfur dioxide, nitrogen oxides and carbon dioxide,
over a compliance period. Emission credits held for use are amortized to cost of operations based the weighted average cost of the allowances