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SEC Comment Response

 2801 Post Oak Blvd.

 Suite
600

 Houston, Texas 77056

Tel: 713/960-9111

 Fax: 713/960-9420

 Via EDGAR and Federal Express

June 30, 2014

 Pamela Long

Assistant Director

 United States Securities and Exchange
Commission

 Division of Corporation Finance

 100 F Street,
N.E.

 Washington, D.C. 20549-3561

Re:
Westlake Chemical Partners LP

Amendment No. 1 to Registration Statement on Form S-1

Filed June 6, 2014

File No. 333-195551

 Ladies and Gentlemen:

Set forth below are the responses of Westlake Chemical Partners LP (the “Partnership”,
“we,” “us” or “our”), to comments received from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission
(the “Commission”) by letter dated June 20, 2014, with respect to Amendment No. 1 to Registration Statement on Form S-1, File No. 333-195551, filed with the Commission on June 6, 2014 (the
“Registration Statement”).

 Concurrently with the submission of this letter, we have
filed through EDGAR Amendment No. 2 to the Registration Statement (“Amendment No. 2”). For your convenience, we have also hand delivered five copies of this letter, as well as five copies of Amendment
No. 2 marked to show all changes made since the first amendment to the Registration Statement.

 For your convenience,
each response is prefaced by the exact text of the Staff’s corresponding comment in bold, italicized text. All references to page numbers and captions correspond to Amendment No. 2 unless otherwise specified. Capitalized terms used in this
response letter, but not defined herein, have the meanings given to them in the Registration Statement.

 General

1.
We note your response to comment 5 in our letter dated May 22, 2014. Please provide us with copies of the materials that you will send to potential participants in the directed unit program prior to use, or
tell us why you believe you are not required to do so.

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June 30, 2014

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 RESPONSE: We acknowledge the Staff’s comment and undertake to provide copies of
the requested materials when the drafts have been substantially completed, and in advance of their use.

 Risk Factors, page 21

OpCo is a restricted subsidiary and guarantor under Westlake’s credit facility . . ., page 24

2.
We note your response to comment 15 in our letter dated May 22, 2014. We note that you have not filed all of the schedules to Westlake’s credit agreement. Please file all of the schedules of the credit
agreement with your next amendment.

 RESPONSE: We acknowledge the Staff’s comment and have revised the
exhibit index to incorporate the credit agreement with all of the schedules.

 Cash Distribution Policy and Restrictions on Distributions, page 48

3.
Given that you use the title “distributable cash flow,” it appears likely that the measure will be understood by investors to reflect the amount of 2013 cash flow that could have been distributed to the
unit holders. Please explain how your calculation addresses the cash flow impact necessitated by working capital requirements or the reasons you believe the use of $56.9 million for working capital is not relevant to your measure. Also, explain how
you have considered the $6.9 million paid to settle derivatives, as well as potential debt repayments in developing your measure. If the measure is intended solely as a performance measure, please tell us why you believe it is appropriate to refer
to “cash” in the title of the measure and consider revising disclosure throughout the filing to remove the implication it is a cash flow measure. See Item 10(e)(1)(ii)(E) of Regulation S-K and Section 100(b) of Regulation G.

 RESPONSE: We acknowledge the Staff’s Comment and, given that the measure is intended solely as a
performance measure, we have revised the Registration Statement to include a presentation of “adjusted current earnings” instead of “distributable cash flow.”

4.
If you determine that your non-GAAP measure is a liquidity measure, then you must include reconciliation to GAAP operating cash flows or the most directly comparable pro forma measure prepared and presented in
accordance with Article 11 of Regulation S-X. See Item 10(e)(1)(i)(B) of Regulation S-K and Question 101.02 of the Division’s Non-GAAP Financial Measures Compliance & Disclosure Interpretations. Further, you must also present the
three major categories of the statement of cash flows with equal prominence pursuant to Question 102.06 of the Division’s Non-GAAP Financial Measures Compliance & Disclosure Interpretations.

RESPONSE: We acknowledge the Staff’s comment. As set forth in our response to the Staff’s comment number 3 above, we have
revised the Registration Statement to refer to “adjusted current earnings” instead of “distributable cash flow,” and to reconcile this measure to GAAP operating cash flow as discussed with the Staff. As indicated in our response
to the

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Staff’s comment number 3 above, the Partnership does not view “adjusted current earnings” as a liquidity measure.

5.
Please explain to us how the “Borrowings by OpCo from Westlake to fund expansion capital expenditures” pro forma adjustment is factually supportable and consistent with your disclosure that the measure
“provides useful information to investors in assessing our results of operations.” The existing presentation states that $26.3 million of “distributable cash flow” was generated from your 2013 operations, when it appears $18.3
million of that amount is assumed to be proceeds from borrowings. See the guidance in Article 11-02(b)(6) of Regulation S-X and Section 100(b) of Regulation G.

RESPONSE: We acknowledge the Staff’s comment. As set forth in our response to the Staff’s comment number 3, we have revised
the Registration Statement to present a calculation of “adjusted current earnings” instead of “distributable cash flow.” As described in Amendment No. 2, “adjusted current earnings” does not take into account
expansion capital expenditures or external financing thereof, and we have removed the adjustment for “Borrowings by OpCo from Westlake to fund expansion capital expenditures”.

6.
Please tell us whether you intend to revise the interest expense and interest paid amounts herein to correspond with the amounts ultimately shown in your pro forma Statements of Operations. In this regard, it
appears adjustment (n) on page F-4 cannot be completed until you can estimate the debt repayment.

RESPONSE: We acknowledge the Staff’s comment and intend to revise the interest expense and interest paid amounts to correspond
with the amounts ultimately shown in our pro forma Statements of Operations.

7.
Wherever you present this non-GAAP measure, please disclose the extent to which it has been impacted by non-recurring items like the $5.4 million derivatives gain on page F-31 and the $3.2 million claims recovery
on page F-35. See Article 11-02(c)(4)

 RESPONSE: We acknowledge the Staff’s comment. We have revised the
Registration Statement to clarify that derivative gains and losses have been eliminated as activity included in the Predecessor that will not be a part of OpCo’s operations after the execution of the Ethylene Sales Agreement. We respectfully
submit that the claims recovery was previously disclosed as being eliminated in the pro forma adjustments. Please see notes (i) (in relation to derivative gains and losses) and (1) (in relation to the claims recovery) to the pro forma
combined carve-out financial statements on page F-8 of Amendment No. 2.

 Estimated Distributable Cash Flow for the Twelve Months Ending
June 30, 2015, page 49

8.
 We note your response to comment 25 in our letter dated May 22, 2014. Please remove the language in the last paragraph on page 55 stating
that you do not undertake any obligation to release publicly the results of any future revisions you may make to the assumptions used in generating your distributable cash flow, or revise the disclosure to clarify that you will update the disclosure
as necessary to reflect any material future

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June 30, 2014

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revisions. This statement may suggest to investors that you are not responsible for the material facts necessary to make your statements not misleading at the time of sale or contract of sale.

 RESPONSE: We acknowledge the Staff’s comment and have revised the Registration Statement to remove the
language.

 Capital Resources and Liquidity, page 86

9.
Please disclose the amount of borrowing availability under the revolving credit facility as of March 31, 2014.

RESPONSE: We acknowledge the Staff’s comment and have revised the Registration Statement to include the amount of borrowing
availability under the revolving credit facility as of March 31, 2014. Please see page 88 of Amendment No. 2.

 Unaudited Pro Forma
Combined Carve-Out Financial Statements, page F-1

10.
We note your response to comment 24 of our letter dated May 22, 2014. Please disclose in note (j) to the pro forma financial statements your basis for determining that the omnibus agreement will result
in a lower allocation of selling, general and administrative expenses. Please also disclose how you arrived at the amounts reflected in adjustment (j).

RESPONSE: We acknowledge the Staff’s comment. The omnibus agreement requires OpCo to reimburse Westlake for certain direct and
indirect expenses incurred by Westlake and its affiliates, including for services provided by Westlake employees in capacities equivalent to corporate executive officers. Management incentive compensation reflected in the Predecessor’s
financial statements was based on the totality of earnings and activities in the Predecessor’s financial statements. As some of the earnings and activities will be retained by the Predecessor, management incentive compensation allocated to OpCo
would have been lower for the applicable pro forma periods. Accordingly, the pro forma adjustment to selling, general and administrative expenses reflects the portion of the management incentive compensation in the Predecessor’s financial
statements related to the activities and earnings to be retained by the Predecessor. We have revised note (j) to the pro forma combined carve-out financial statements. Please see page F-8 of Amendment No. 2.

We respectfully note that under the pricing provision of the Ethylene Sales Agreement, the ethylene price per pound to be paid by Westlake
includes a reimbursement component for cash operating expenses, including selling, general and administrative expenses, incurred by OpCo (the “Operating Cost Reimbursement”). The Operating Cost Reimbursement is a function of forecasted
dollars per pound, for each identified cost category, and actual production delivered to Westlake under the Ethylene Sales Agreement. For pro forma purposes, we have assumed that pro forma operating costs associated with the portion of
ethylene assumed to have been consumed internally (i.e., 95% as disclosed in note (h) to the unaudited pro forma combined carve-out financial statements) are reimbursed by Westlake under the Ethylene Sales Agreement.

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Accordingly, the impact on pro forma income before income taxes for any pro forma adjustment to either reduce or increase cash operating costs is mitigated by an offsetting adjustment
to revenue equal to approximately 95% of the cash operating costs adjustment.

11.
We note your response to comment 33 of our letter dated May 22, 2014. We note that OpCo will enter into two site lease agreements with Westlake related to the Lake Charles Olefins and Calvert City Olefins for
$1 per site per year. Please tell us what consideration was given to SAB Topic 1:B related to your use of these two sites in both your historical financial statements as well as in the pro forma financial statements.

RESPONSE: We have included in our Predecessor’s combined carve-out financial statements all assets that were historically part of
Westlake’s ethylene business, including the historical balances for land and land improvements underlying our Lake Charles Olefins and Calvert City Olefins production facilities. Our historical combined carve-out statements of operations
reflect charges for actual depreciation incurred on capitalized land improvement in accordance with SAB Topic 1:B.

 The land underlying
our Lake Charles Olefins and Calvert City Olefins production facilities will not be contributed to OpCo in connection with this offering. The land and land improvements covered by the two site lease agreements are included as a reduction to
property, plant and equipment in adjustment (a) to the pro forma combined carve-out financial statements. We have also adjusted the associated depreciation on land improvements as a reduction to cost of sales in adjustment (i) to the pro
forma combined carve-out financial statements.

 As set forth in our response to the Staff’s comment number 10, under the pricing
provision of the Ethylene Sales Agreement, the ethylene price per pound to be paid by Westlake includes a reimbursement component for cash operating expenses incurred by OpCo. Accordingly, the impact on pro forma income before income taxes for
any pro forma adjustment to either reduce or increase cash operating costs is mitigated by an offsetting adjustment to revenue equal to approximately 95% of the cash operating costs adjustment.

We have revised the Registration Statement to clarify that the shared service assets described in adjustment (a) in the footnotes to the
pro forma combined carve-out financial statements include the land and land improvements underlying Lake Charles Olefins and Calvert City Olefins. Please see page F-6 of Amendment No. 2.

Note 8. Related Party Transactions, page F-26

12.
We note your response to comment 40 of our letter dated May 22, 2014. Please help us better understand how an allocation of selling, general and administrative expenses on the basis of fixed assets would be a
reasonable reflection of the utilization of services provided or the benefit received by the Predecessor during the periods presented. It is not clear how fixed assets would be a reasonable basis to allocate employee-related costs, which your
response indicates represent the majority of this allocation.

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 RESPONSE: For the purposes of the Predecessor’s combined carve-out financial
statements, costs incurred by the Parent are allocated to us in accordance with SAB Topic 1:B using a proportional allocation methodology. The methodology by which we allocate costs incurred by the Parent on our behalf utilizes a number of
allocation bases. The following table presents, by allocation methodology, costs included in the combined carve-out statements of operations that were incurred by the Parent on our behalf:

 Financial Statement Line Item

 Allocation Methodology

2013

2012

2011

(dollars in thousands)

 Cost of sales

Actual payroll and other costs incurred

$
61,770

$
57,454

$
51,500

 Selling, general and administrative expenses

Actual payroll and other costs incurred

3,857

3,920

4,669

 Selling, general and administrative expenses

Relative fixed assets, headcount or other measure

20,197

18,565

16,491

 We specifically identify expenses that can be clearly attributed to the Predecessor’s business and
allocate those costs to the Predecessor. As noted in the table above, a majority of costs incurred by our Parent and allocated to the Predecessor are specifically identifiable and are directly reflected in the Predecessor’s combined carve-out
statements of operations. Due to the nature of costs incurred by our Parent, for which specific identification is possible, costs that are directly attributed to us are predominantly reflected in cost of sales, with