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 May 22, 2025

Michael Garrett, CPA
Vice President of Accounting and Controller
Diversified Energy Co PLC
1600 Corporate Drive
Birmingham, Alabama 35242

 Re: Diversified Energy Co PLC
 Form 20-F for the Fiscal Year ended December 31, 2024
 Filed March 17, 2025
 File No. 001-41870
Dear Michael Garrett, CPA:

 We have reviewed your filing and have the following comments.

 Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 20-F for the Fiscal Year ended December 31, 2024
Key Facts for 2024, page 4

1. We note that PV-10 is not calculated in accordance with IFRS and is
disclosed to be
 an alternative performance measure on page 152. Please revise to include
the
 reference (a) for the information on how this metric is calculated and
reconciled to the
 most directly comparable IFRS measure.
Our Business
Reserve Data
Summary of Reserves, page 8

2. Please expand the proved reserve tables on pages 8, 10 and 145 to
include a footnote
 to clarify the basis for converting oil and NGL volumes to natural gas
equivalent
 volumes (e.g. the number of standard cubic feet of natural gas per one
barrel of oil).
 Refer to Instruction 3 to Item 1202(a)(2) of Regulation S-K.

 In addition, please include a similar footnote with the tables
presenting production on
 May 22, 2025
Page 2

 pages 13, 21, and 145.
Proved Reserves, page 9

3. We note the Extensions and Discoveries during 2023 and 2024 are
explained as
 adjustments due to well assignments recorded in the accounting
actuals. Please
 expand your explanation to clarify why these adjustments are not
considered as
 revisions in previous estimates. Refer to the disclosure requirements in
FASB ASC
 932-235-50-5.
Proved Undeveloped Reserves, page 10

4. Please expand your discussion of the changes due to conversions to
include the dollar
 amount of capital incurred to convert proved undeveloped reserves to
proved
 developed reserves. Refer to the disclosure requirements in Item 1203(c)
of
 Regulation S-K.
Reserve Data
Significant Fields, page 13

5. You disclose total production for the Appalachian Region because you
determined it
 is considered significant or greater than 15% of total proved reserves.
Please tell us
 how you also comply with the disclosure requirements at Item 1204(b) of
Regulation
 S-K.
Supplemental Natural Gas & Oil Information (Unaudited)
Estimated Reserves, page 145

6. Please expand the tabular presentation of proved developed and proved
undeveloped
 reserves by individual product type on page 146 to provide the net
quantities at the
 beginning of the initial year shown in the reserves reconciliation, e.g.
December 31,
 2021. Refer to the disclosure requirements in FASB ASC 932-235-50-4.
Standardized Measure of Discounted Future Net Cash Flows, page 146

7. We note your standardized measure calculation, as of December 31, 2024,
includes a
 positive 10% annual discount value of $253.1 million. This calculation
creates a
 standardized measure of $1,396.9 million which is higher than the
presented value for
 future net cash flows of $1,143.8 million. Please review and revise if
necessary, here
 and elsewhere in your filing, to remove the inconsistency or expand your
disclosure to
 explain the circumstances resulting in the positive 10% discount
adjustment. Refer to
 the disclosure requirements in FASB ASC 932-235-50-31 and 50-36.
Alternative Performance Measures, page 150

8. We note your presentation includes the measures Pro forma adjusted
EBITDA and
 Net-debt-to-pro forma adjusted EBITDA. Pleas revise to provide the
disclosures and
 presentation requirements to comply with Article 11 of Regulation S-X
and Question
 100.05 of the Compliance and Disclosure Interpretations on Non-GAAP
Financial
 Measures.
 May 22, 2025
Page 3
9. We refer you to PV-10 presented on page 152. Please include a footnote
that provides
 a description of why the adjustment for PV of taxes differs from the
amounts
 presented as future income tax expense used to determine the
standardized measure
 presented on page 147.
PV-10, page 152

10. The PV-10 value presented of $1,591.8 million is higher than the total
undiscounted
 future net cash flows of $1,447.7 million (before future income tax
expenses) in the
 standardized measure calculation on page 147. If correct, please provide
us a detailed
 explanation. Please review and revise if necessary, here and elsewhere
in your filing,
 to remove the inconsistency or expand your disclosure to explain the
circumstances
 resulting in the pre-tax PV-10 value of $1,591.8 million for the year
ended December
 31, 2024. This comment also applies to the disclosure in Exhibit 15.3.

 We remind you the company and its management are responsible for the
accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or
absence of
action by the staff.

 Please contact Brian McAllister at 202-551-3341 or Kimberly Calder at
202-551-3701
if you have questions regarding comments on the financial statements and
related matters.
Please contact Sandra Wall, Petroleum Engineer, at 202-551-4727 or John Hodgin,
Petroleum
Engineer, at 202-551-3699 with questions regarding the engineering comments.
Please
contact Brad Skinner, Office Chief, at 202-551-3489 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Energy &
Transportation
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