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CORRESP
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CORRESP

 September 26, 2014

Mr. H. Roger Schwall, Assistant Director

 Division of
Corporation Finance

 U.S. Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549-3628

Re:
SandRidge Energy, Inc.

File No. 001-33784

 Dear Mr. Schwall,

SandRidge Energy, Inc. (the “Company” or “SandRidge”) hereby submits this letter in response to the comment
letter (the “Letter”) of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”), sent via email on August 15, 2014, which addresses subjects that have been
the subject of comment letters and an email previously sent by the Staff (on July 30, 2013; November 13, 2013; February 4, 2014; and June 3, 2014) and responded to by the Company (on August 21, 2013; December 13,
2013; February 19, 2014; and August 19, 2014).

 Set forth below is the text of each comment set forth in the Letter, followed by
our response thereto. Capitalized terms used but not otherwise defined herein have the respective meanings ascribed to them in the Company’s annual report on Form 10-K for the year ended December 31, 2012.

Comment

 Revenue Recognition and Natural Gas
Balancing, page F-13

 1. We note that you have not complied with prior comment 5 of our comment letter dated February 4, 2014, regarding
income you have recognized for services performed on behalf of third-parties having interests in wells that you operate. We previously advised that Rule 4-10(c)(6)(iv)(C) of Regulation S-X precludes your reliance on the guidance in Rule
4-10(c)(6)(iv)(B), under these circumstances, in stating that “notwithstanding the provisions of paragraphs (i)(6)(iv) (A) and (B) of this section, no income may be recognized for contractual services performed on behalf of investors
in oil and gas producing activities managed by the registrant or an affiliate.” We also previously advised that we regard an operator of oil and gas properties to be a manager that is subject to the prohibition imposed by this guidance. We
continue to believe you will need to revise your accounting policy to conform. If you believe the resulting errors in your accounting are not material and you prefer to limit compliance to future filings, please submit the analysis that you
performed in formulating your view.

 Mr. H. Roger Schwall

U.S. Securities and Exchange Commission

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 Response

The Company and PwC, our independent auditor, continue to view the role of an operator of oil and gas assets as different from that of a manager of such
assets. For this reason, the Company requests that this matter be referred to the Office of the Chief Accountant for resolution. However, the Company notes that it has performed a quantitative and qualitative assessment of the materiality of the
changes to the Company’s statement of operations that would be necessitated by the Staff’s interpretation, and believes that the impact of such changes would not have been material to the 2013 Form 10-K. The Company will provide this
analysis, if necessary, pending resolution of this Comment by the Office of the Chief Accountant.

 Comment

Note 12—Construction Contracts, page F-34

2. We have read your response to prior comment one, setting forth your views on the accounting for both the annual, and end-of-contract CO2 delivery
shortfall liabilities, and understand that while you believe FASB ASC 450-20 is applicable, you have not accrued a liability for the end-of-contract penalty because you do not yet consider payment to be probable and estimable. However, we also note
that you recorded a liability for the 2013 annual CO2 delivery shortfall on December 31, 2013, even though the amount appears to have been estimable in an earlier period of time and possibly at the beginning of 2013. For example, you disclose
on pages 6, 78 and F-42 of your 2012 Form 10-K that “the Company expects to accrue between $29.5 million and $36.0 million at December 31, 2013,” due to the penalty provisions of the treating agreement.

We understand that your annual delivery requirements would be assessed on a calendar year basis under your agreement in applying FASB 450-20.
Accordingly, you should recognize the probable loss each fiscal quarter once it becomes reasonably estimable, i.e. when you expect an annual shortfall to occur and require a penalty payment on January 1 of the following calendar year, as a
liability pursuant to FASB ASC 450-20-25-1 and 25- 2. A similar approach should be applied to the end-of contract penalty provisions.

Please revise your financial statements accordingly; if you believe the effects would not be material and prefer to limit compliance to future filings,
please submit the analysis underlying your view. In either case, please revise your disclosures under this heading and MD&A where indicated and appropriate, to include the following information.

•

The cumulative under-delivered quantity of CO2 at each balance sheet date, the amount of the possible end-of-contract penalty related to this quantity, and the extent to which this has been accrued
each period based on your probability assessments.

 Mr. H. Roger Schwall

U.S. Securities and Exchange Commission

  Page
 3

•

The annual penalty that will arise based on current period under-deliveries unless over-deliveries are made during the remainder of the year, and the extent to which this has been accrued each period
based on your probability assessments.

•

Any constraints on your ability to over-deliver CO2 in future years to offset the cumulative under-deliveries to date, including a discussion of plant capacity, and the manner by which this is shared
with the counterparty.

•

Any reasonably possible future delivery scenarios having material implications should be addressed in MD&A (e.g., the extent to which you are expecting delivery shortfalls to continue should be
addressed if it is reasonably possible that future over-deliveries will be materially insufficient to offset these amounts).

•

Salient details of the provisions which govern your ability to reduce liquidating damages and to terminate the contract early, including the amounts you would need to pay, the manner in which these
are calculated at any given date, and your assessment of any reasonably possible scenarios evoking these provisions.

•

Clarify the meaning of the language “net of any accrued annual shortfalls” that is used on page 31 of your June 30, 2014 Form 10-Q in discussing the remaining quantities to be
delivered under your contract.

•

The annual and end-of-contract penalty per Bcf amounts should accompany any related discussion of the CO2 delivery shortfalls.

Response

 As explained in prior submissions, the
Company entered into the contract with the annual CO2 delivery shortfall provision with the expectation that sufficient volumes of CO2 would be extracted from the Company’s equity production. While near term natural gas pricing caused the
Company to defer its development of the resource behind the Century processing facility, the Company has the ability to mitigate the shortfall payment by purchasing unprocessed natural gas with sufficient CO2 content from other producers and have
such natural gas delivered and processed at the Century Plant, subject to the plant’s daily operational limitations. The Company believes that its ability to mitigate the annual shortfall payment in this fashion must be considered when and if
an annual CO2 delivery shortfall should be recorded, as explained below:

 The Company considered three potential approaches for determining the proper
accounting of the annual under delivery penalties: 1) accruing the entire annual shortfall payment in the first quarter of a year, 2) accruing a prorated quarterly amount of the annual shortfall each quarter and 3) a process that accrues the
estimated annual shortfall penalty during a year based on remaining available processing capacity. The Company’s assessment of each approach is as follows:

 Mr. H. Roger Schwall

U.S. Securities and Exchange Commission

  Page
 4

1.
Accrual of the entire annual shortfall payment in the first quarter. As noted within FASB ASC 450-20-25-2 with respect to loss contingencies, accrual of probable losses is required when such losses are
reasonably estimable and relate to the current or a prior period. The estimate disclosed in the 2012 Form 10-K of the expected accrual for the 2013 shortfall penalty with respect to the annual delivery obligation was based solely upon forecasted
deliveries from currently producing wells for 2013 as of the time of the filing of the 2012 Form 10-K and did not consider other methods by which the Company could fulfill its delivery obligation under the contract, such as purchasing unprocessed
natural gas with sufficient CO2 content from other producers or drilling additional wells in the area. An accrual of the entire annual shortfall penalty in the first quarter of 2013 would not have been appropriate under these facts and circumstances
because such liability would not comply with the characteristics of a liability as described in CON 6 paragraph 36. Specifically, the event obligating the Company (i.e., the annual calculation) had not occurred at the end of the first quarter and
the Company had discretion to avoid or mitigate such liability subject to the plants’ operations constraints described below.

2.
Accrual on a prorated quarterly basis. Because under delivery penalties are determined under the treating agreement based upon an annual commitment and not a monthly or quarterly delivery commitment (e.g.,
there is no penalty assessed against the Company if one-fourth of the annual requirement is not delivered within any particular quarter), there is no periodic delivery requirement, other than an annual requirement, against which to measure monthly
or quarterly deliveries in order to determine an obligation attributable to current or prior periods as required by the guidance in ASC 450-20-25-2. Any obligation accrued monthly or quarterly based upon forecasted deliveries would not relate to
current or prior periods and, therefore, would not be in accordance with the guidance of ASC 450. Further, just like a first quarter accrual of the entire shortfall liability discussed above, this method produces a liability that is inconsistent
with CON 6 paragraph 36.

3.
Accrual based on remaining available processing capacity. Because the treating agreement does not include monthly or quarterly minimum delivery requirements, only an annual requirement, the Company
believes the amount of annual shortfall payment is not considered reasonably estimable and related to a current or prior period until sufficient capacity is no longer available over the remainder of the year to meet the annual obligation, as
described in greater detail below. An analysis of actual deliveries and processing capacity for the first eight months of 2014 and the year ended December 31, 2013 is as follows:

Eight Months Through August 31, 2014

The total daily capacity of the Century Plant and the Company’s legacy gas processing plants (from which CO2 resulting from natural gas
processing may also be delivered to Occidental for application toward the annual delivery requirement) that are operational in 2014 is 845 MMCF. Based on the Company’s 2014 actual CO2 deliveries through June 30, 2014, totaling 10,485 MMCF,
the Company’s remaining annual delivery requirement for 2014, net of banked allowable volumes (CO2 delivered from the Company’s legacy plants to Occidental for a specified time prior to completion of the Century Plant, limited to 0.833% of
the annual delivery requirement per the treating agreement), was 145,982 MMCF as of that date. With an available daily processing capacity of 845 MMCF, approximately 173 days of processing capacity would be required to meet the remaining annual
delivery requirement and, as of June 30, 2014, 184 days remained in the calendar

 Mr. H. Roger Schwall

U.S. Securities and Exchange Commission

  Page
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year. With sufficient capacity available in the remainder of the year to meet the annual obligation, which the Company could accomplish by purchasing gas from other producers, drilling additional
wells in the area or a combination of these activities, a loss for the annual obligation is not considered probable, estimable and related to a current or prior period as of June 30, 2014, (i.e., since not yet related to a current period, a
loss has not yet been incurred). The Company analyzed deliveries subsequent to June 30, 2014 and determined that as of July 31, 2014, approximately 171 days of processing capacity were required in order to meet the remaining annual
delivery requirement and only 153 days remained in the calendar year. Therefore, the Company will accrue an estimate of the annual shortfall in the third quarter of 2014 financial statements that is probable, estimable and related to this period,
based upon the shortage of available capacity as of the end of this period and will update the accrued amount at the end of each monthly period through the remainder of the calendar year. As of August 31, 2014, with a shortage of approximately
47 days, or 39,344 MMCF based on daily capacity limits, the estimated amount to be accrued for the 2014 annual under delivery penalty is approximately $9.8 million, which represents the minimum estimable 2014 loss relating to current or prior
periods as of that date in accordance with ASC 450-20-30-1, which states “When no amount within the range is a better estimate than any other amount, however, the minimum amount in the range shall be accrued. Even though the minimum amount in
the range is not necessarily the amount of loss that will be ultimately determined, it is not likely the ultimate loss will be less than the minimum amount.”

2013

 The Company
performed the same analysis for 2013, based on total daily capacity of the Century Plant and the Company’s legacy plants that were operational in 2013 of 1,066.5 MMCF, and determined a portion of the 2013 loss was probable, estimable and
related to a current or prior period in the third quarter of 2013 since as of September 30, 2013, approximately 128 days of processing capacity were required in order to meet the remaining annual delivery requirement and only 92 days remained
in the calendar year. As of September 30, 2013, with a shortage of approximately 36 days, or 38,104 MMCF based on daily capacity limits, the estimated amount to be accrued for the 2013 annual under delivery penalty was approximately $9.5
million, which represents the minimum estimable 2013 loss relating to current or prior periods as of that date in accordance with ASC 450-20-30-1, which states “When no amount within the range is a better estimate than any other amount,
however, the minimum amount in the range shall be accrued. Even though the minimum amount in the range is not necessarily the amount of loss that will be ultimately determined, it is not likely the ultimate loss will be less than the minimum
amount.”

 For the reasons set forth below, the Company does not believe the correction of the third quarter 2013 financial statements,
i.e., by recording an accrual of $9.5 million in respect of the 2013 delivery shortfall penalty, represents the correction of a material error in the prior period financial statements. Below is the Company’s analysis that demonstrates that the
impact of the aforementioned under delivery penalty is not material from both a quantitative and qualitative perspective.

 Mr. H. Roger Schwall

U.S. Securities and Exchange Commission

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 An analysis of the impact of the estimated under delivery penalty not accrued at
September 30, 2013 to reported amounts is as follows:

YTD September 30, 2013

QTD September 30, 2013

QTD December 31, 2013

(in thousands)

As
Reported

As
Revised

$
Change

As
Reported

As
Revised

$
Change

As
Reported

As
Revised

$
Change

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