SecProbe.io

Mail Stop 3561
May 18 , 2016

Matthew C. Liuzzi
Vice President, Chief Financial Officer and Treasurer
USA Compression Partners, LP
100 Congress Avenue, Suite 450
Austin, TX 78701

Re:  USA Compression Partners, LP
 Form 10 -K for the Fiscal Year Ended December 31, 2015
Response dated May 5, 2016
Form 8 -K
Filed May 5, 2016
Form 10 -Q for the Fiscal Quarter Ended March 31, 2016
Filed May 5, 2016
File No. 001 -35779

Dear Mr. Liuzzi:

We have reviewed  your May 5, 2016  response to our comment  letter  and have the
following comment s.  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.
Unless we note otherwise, our references to prior comments are to comments in our April 21,
2016  letter.

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

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

General Trends and Outlook, page  45

1. Your response to comment 1 indicates that your compression fleet can be quickly and
cost-effectively modified and moved between shale plays and disclosure of your
horsepower by shale or region would not provide meaningful information to your
investors.  To  assist us in better understanding your response, please tell us how

Matthew C. Liuzzi
USA Compression Partners, LP
May 1 8, 2016
Page 2

 frequently you move your equipment between shale plays.  Please also tell us the average
time and costs associated with redesigning and deploying such equipment during the year
ended Dece mber 31, 2015, or during the most recent year in which you moved equipment
between shale plays.

2. Your response to the first bullet point of comment 2 describes various ways in which you
monitor your customers’ credit quality.  Please consider revising yo ur critical accounting
policy addressing your allowance for doubtful accounts to explain in more detail the
estimates and judgments you make about your customers’ ability to pay and any trends
you have observed in your customers’ credit quality rather than  simply stating that you
make estimates and judgments and that you evaluate your customers’ financial strength.
Additionally, since it appears from your response that you monitor your customers’ credit
ratings, please tell us whether any of your largest c ustomers have credit ratings below
investment grade, and tell us how you considered disclosing this information as part of
providing investors with insight into the potential risks to and variability of your earnings
and cash flows.

3. We note your response to the second bullet point of comment 2.  Given your risk factor
disclosures about the possible impact of contract renegotiations, we believe you should
clearly disclose in future filings, if true, that these negotiations did not have  a material
impact on your results of operations.  We believe clarifying the impact of these contract
negotiations provides important information to your investors.

4. We note your response to the third bullet point of comment 2.  Please tell us how the
service rates for your month -to-month contracts differed from the service rates for
contracts in their primary term during 2015, including whether they were generally above
or below the rates for contracts in their primary term.  In future filings, please di sclose
this information for the periods presented, including if applicable making an affirmative
statement that rates for month -to-month contracts did not significantly differ from rates
for contracts in their primary term.  Given that a significant percen tage of your contracts
are operating on a month -to-month basis and the increased ability of these customers to
renegotiate pricing or terminate service as compared to customers with contracts in their
primary term, we believe that explaining in more detail  the impact of month -to-month
contracts on your results and any factors that cause these contracts to have significantly
different impacts on your consolidated results and cash flows as compared to contracts in
their primary term provides important informa tion to your investors.

Financial Results of Operations, page 49

5. We note your response to comment 4.  As the circumstances under which you evaluate
compression units for impairment and the specific factors that led to recording a
significant impairment  charge related to your compression equipment in 2015 were not
clearly disclosed in your Form 10 -K, please revise future filings to provide this
information in appropriate locations, such as your accounting policy footnote or critical

Matthew C. Liuzzi
USA Compression Partners, LP
May 1 8, 2016
Page 3

 accounting policy and  your analysis of results when you describe the impairment
recorded in 2015.  We believe that disclosing information similar to that contained in
your response will be useful to your investors.

Financial Statements for the Year Ended December  31, 2015

Note (2) – Summary of Significant Accounting Policies

(c) Inventories, page  F-8

6. Your response to comment 6 indicates that your inventory cost flow assumptions have
not changed.  Please tell us why you disclosed FIFO as your inventory cost flow
assumption  in 2013, and prior years, if you were using the specific identification or
weighted average cost method.  Also tell us how you considered whether this apparent
error in your accounting policy disclosure indicated a deficiency in your disclosure
controls a nd procedures and whether this deficiency has been remediated.  We note that
you concluded your disclosure controls and procedures were effective in each of your
fiscal 2014 Forms 10 -Q and that the conclusion in your 2014 Form 10 -K solely refers to
the lac k of timely filing a Form 8 -K announcing a change to your general partner’s board
of directors.

Form  8-K filed May 5, 2016

7. We note your response to comment 8 indicating you will not give equal or greater
prominence to non -GAAP measures in future filings.   We also note that you furnished
under Item 2.02 of Form  8-K a press release describing your earnings for the first quarter
of 2016, and this press release continued to give prominence to your non -GAAP
measures.  Please confirm that in future earnings rel eases you will not give greater
prominence to non -GAAP measures than you do to the most directly comparable GAAP
measures, consistent with the guidance in Item 10(e)(1)(i)(A) of Regulation S -K.

Form  10-Q for the Fiscal Quarter Ended March  31, 2016

Notes to the Unaudited Condensed Consolidated Financial Statements

Note (1) – Organization and Summary of Significant Accounting Policies

(f)  Property and Equipment, page 6

8. We note that you revised the estimated useful life of your compression equipment from
25 years to 20 – 25 years.  Please explain to us the nature of the change in useful life and
tell us why you believe it was appropriate to make the change in the first quarter of 2016
rather than during 2015.  As part of your response, tell us whether thi s change relates
solely to new equipment acquired during 2016.  If not, please revise to disclose the effect

Matthew C. Liuzzi
USA Compression Partners, LP
May 1 8, 2016
Page 4

 on net income and any related per -share amounts for the current period, if material.  See
ASC 250 -10-50-4.

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

Operating Highlights, page 15

9. We note that you present multiple measures of horsepower utilization, including average
horsepower utilization based on revenue generating horsepower and fleet horsepower.
We u nderstand this specific metric to effectively reflect the average amount of your
horsepower earning revenue during the period as a percentage of your total horsepower
received from suppliers and available to earn revenue.  We also understand the difference
between this metric and 100% reflects your average idle horsepower during the period.
Please confirm our assumptions, or if our understanding is not correct, explain this matter
to us in detail and revise future filings to better explain this metric to y our investors.  If
our understanding is correct, please provide us with management’s detailed view of why
this utilization metric shows a pattern of decline across the last several quarters, or
conversely, why you appear to have a trend of increasing perce ntages of your horsepower
that is available to earn revenue sitting idle and not earning revenue.  In doing so, please
clearly explain the extent to which this decreasing utilization is due to increased amounts
of equipment idle due to repairs and maintena nce, the extent to which it is due to
acquiring new compression units before you have service contracts for those units, the
extent to which it is due to increased equipment returned by your customers for which a
new revenue generating use has not been fou nd, and any other applicable factors.  Also
tell us in detail how you determined this trend did not need to be disclosed and the
underlying factors driving this trend analyzed in your MD&A, and if this trend continues,
please disclose and analyze it.

You may contact Melissa Blume, Staff Accountant at (202) 551 -7128 or me at (202) 551 -
3737 if you have questions regarding comments on the financial statements and related matters.

Sincerely,

 /s/ Jennifer Thompson

Jennifer Thompson
Accounting Branch Chief
Office of Consumer Products