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Mailstop 4628
       October 7 , 201 6

Via E -mail
Mr. Don E. Wallette, Jr.
Chief Financial Officer
ConocoPhillips
600 North Dairy Ashford
Houston, Texas  77079

 Re: ConocoPhillips
  Form  10-K for the Fiscal Year Ended December 31 , 2015
Filed February 23, 2016
Form  8-K Filed July 28, 2016
Response Letter Dated September 12, 2016
File No. 1-32395

Dear Mr. Wallette :

We have reviewed your filing s and response 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 s.

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.   Unless we not e otherwise, our references to prior comments are to comments in our
August 26, 2016 letter .

Form 10 -K for the Fiscal Year Ended December 31, 2015

Notes to Consolidated Financial Statements

Oil and Gas Operations (Unaudited), page 139

Proved  Undeveloped Reserves, page 150

1. We note your response to prior comment 4 indicating certain proved undeveloped
locations related to the Eagle Ford area will not be developed within five years of their

Mr. Don E. Wallette, Jr.
ConocoPhillips
October 7 , 2016

 initial disclos ure and that after considering the answ er in Question 131.03 in the C&DIs,
you have concluded that continuing to recognize these locations is appropriate.

We are not in a position to agree with your conclusion regarding an exception to the
requirements under Rule 4 -10(a)(31 )(ii) of Regulation S -K based on the facts and
circumstances provided in your response related to your Eagle Ford proved undeveloped
locations.   In this regard, we note your response to prior comment 2 states “by exercising
capital flexibility we have slow ed the pace of certain investments including our drilling
program in the Eagle Ford area” and “this decision did not materially impact our reserves
estimates for the Eagle Ford at fiscal year -end 2015, but did impact the conversion timing
of undeveloped re serves.”  The last bullet in the answer to Question 131.03 indicates
delays in development caused by internal factors such as your decision to slow the pace
of investments relating to your drilling program in the Eagle Ford area  would not warrant
an except ion for a time period longer than five years to begin development of those
reserves .  Please remove any previously disclosed proved undeveloped reserves
attributable to Eagle Ford locations which are not planned to be drilled within five years
of initial d isclosure .

Form 8 -K Filed July 28, 2016

Exhibit 99.1 Press Release

2. Please r evise your presentation of annualized revenue to include disclosure similar to the
explanations provided in your response to prior comment 6 .

You may contact Lily Dang at (202) 551 -3867  or John Cannarella at (202) 551 -3337 if
you have questions regarding comments on the financial statements and related matters.  You
may contact John Hodgin, Petroleum Engineer, at (202) 551 -3699 if you have questions
regarding the enginee ring comments .  Please contact me at (202) 551 -3489 with any other
questions.

        Sincerely,

        /s/ Brad Skinner

Brad Skinner
Senior Assistant Chief Accountant
Office of Natural Resources