United States securities and exchange commission logo
May 15, 2020
Pierre R. Breber
Vice President and Chief Financial Officer
Chevron Corporation
6001 Bollinger Canyon Road
San Ramon, California 94583-2324
Re: Chevron Corporation
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed February 21,
2020
File No. 1-00368
Dear Mr. Breber:
We have reviewed your filing 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.
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.
Form 10-K for the Fiscal Year Ended December 31, 2019
Supplemental Information on Oil and Gas Producing Activities-Unaudited
Table V-Reserve Quantity Information
Proved Undeveloped Reserves, page 97
1. Expand the discussion
of the changes in the net quantities of your proved undeveloped
reserves to include an
appropriate narrative explanation relating to each of the items you
identity, e.g.
revisions, improved recovery, extensions and discoveries, transfers to proved
developed, sales and
acquisitions. To the extent that two or more unrelated factors are
combined to arrive at
the overall change for an item, your disclosure should separately
identify and quantify
each individual factor that contributed to a material change so that
the change in net
reserve quantities between periods is fully explained.
The disclosure of
revisions in the previous estimates of your proved undeveloped reserves
in particular should
identify the individual factors such as the changes caused by
Pierre R. Breber
Chevron Corporation
May 15, 2020
Page 2
commodity prices, well performance, unsuccessful and/or uneconomic
proved
undeveloped locations or the removal of proved undeveloped locations
due to changes in a
previously adopted development plan. Refer to Item 1203(b) of
Regulation S-K.
This comment also applies to the narrative explanations provided
relating to the changes
that occurred in the net quantities of proved crude oil, condensate
and synthetic oil;
natural gas liquids; and natural gas reserves provided on pages 98
through 102 for each
line item shown in the reconciliation, other than production, and for
each of the periods
presented. Refer to FASB ASC 932-235-50-5.
Proved Reserve Quantities, page 98
2. The combined change in the net quantities of proved crude oil,
condensate and synthetic
oil; natural gas liquids; and natural gas reserves attributed to
extensions and discoveries
appears to be significantly greater than the corresponding change in
the net quantities of
proved undeveloped reserves for each of the last three fiscal years
presented. Expand the
discussion of the changes in your total proved reserves attributed to
extensions and
discoveries to explain the reason(s) for this difference. Refer to
FASB ASC 932-235-50-
5.
We remind you that 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.
You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 if
you have
questions regarding the engineering comments. Please contact Brad Skinner,
Office Chief, at
(202) 551-3489 with any other questions.
FirstName LastNamePierre R. Breber Sincerely,
Comapany NameChevron Corporation
Division of
Corporation Finance
May 15, 2020 Page 2 Office of Energy
& Transportation
FirstName LastName
