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April 25, 2023
Jeff Holman
Chief Financial Officer
Magellan Midstream Partners, L.P.
One Williams Center
P.O. Box 22186
Tulsa, OK 74121-2186
Re:Magellan Midstream Partners, L.P.
Form 10-K for the Fiscal Year ended December 31, 2022
Filed February 21, 2023
File No. 001-16335
Dear Jeff Holman:
            We have reviewed your April 10, 2023 response to our comment letter and have the
following comment.  In some of our comments, we may ask you to provide us with information
so we may better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
March 16, 2023 letter.
Form 10-K for the Fiscal Year ended December 31, 2022
Management's Discussion and Analysis of Financial Condition and Results of Operations
Results of Operations, page 40
1.We understand from page 5 of your response to our prior comments that you regard
operating profit as the most directly comparable GAAP measure to your non-GAAP
measure of operating margin because there would be two rather than five reconciling
adjustments, when compared to a GAAP measure of gross margin.

However, your assessment appears to be based on a comparison of gross margin for
product sales alone, e.g. excluding transportation and terminals revenue and associated
costs of revenue, rather than gross margin for the consolidated results of operations.

 FirstName LastNameJeff Holman
 Comapany NameMagellan Midstream Partners, L.P.
 April 25, 2023 Page 2
 FirstName LastName
Jeff Holman
Magellan Midstream Partners, L.P.
April 25, 2023
Page 2

Please revisit your assessment to utilize gross margin for the consolidated results of
operations, which we generally regard as the most directly comparable GAAP measure to
utilize when presenting a non-GAAP margin measure.

Given the similarity of your operating margin label to GAAP terminology, please also
select an alternate label that more clearly reflects its character as a non-GAAP measure, to
use when referring to the measure in MD&A, segment disclosures, and earnings releases,
to comply with Item 10(e)(1)(ii)(E) of Regulation S-K.

As your non-GAAP operating margin presently appears in advance of the measure that
you believe is the most directly comparable GAAP measure in your reconciliation on page
40, revisions will also be necessary to follow the guidance in the answer to Question
102.10(b) of our Compliance & Disclosure Interpretations on Non-GAAP Financial
Measures, to avoid giving undue prominence to your non-GAAP measure of operating
margin. However, as indicated above you may need to utilize consolidated gross margin
as the most directly comparable GAAP measure in the reconciliation.

We suggest that you reposition the non-GAAP measure and reconciliation to a separate
tabulation, to follow the GAAP information shown on page 40. Please submit the
revisions that you propose to address the concerns outlined above regarding the labeling
and reconciliation for your non-GAAP measure of operating margin.

            You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or Robert Babula,
Staff Accountant at (202) 551-3339 with any questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation