June 25, 2019

Kirkland Andrews
Chief Financial Officer
NRG Energy, Inc.
804 Carnegie Center
Princeton, New Jersey 08540

       Re: NRG Energy, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 28, 2019
           Form 10-Q for the Quarterly Period Ended March 31, 2019
           Filed May 2, 2019
           File No. 001-15891

Dear Mr. Andrews:

       We have reviewed your filings 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, 2018

Note 15 - Investments Accounted for by the Equity Method and Variable Interest
Entities
Entities that are not Consolidated, page 165

1.    We note that the during the fourth quarter of fiscal 2018 the Company
offered to Clearway
      Energy, Inc. its ownership interest in Agua Caliente Borrower I, LLC,
which owns a 35%
      interest in Agua Caliente. We also read the comments made by management
in the fourth
      quarter 2018 earnings transcript regarding waiting for a "better
environment" to monetize
      Agua Caliente after the unsuccessful sale to Clearway Energy, Inc.
Summarize for us the
      circumstances with the current environment which prevented the sale of
Agua Caliente.
      Furthermore, we have read your disclosure regarding Agua Caliente's and
Ivanpah's PPA
      contract exposure related to the PG&E Bankruptcy filing. Please tell us
whether Agua
      Caliente or Ivanpah were experiencing collection issues with PG&E in the
fourth quarter
 Kirkland Andrews
FirstName LastNameKirkland Andrews
NRG Energy, Inc.
Comapany NameNRG Energy, Inc.
June 25, 2019
Page 2
June 25, 2019 Page 2
FirstName LastName
         of fiscal 2018 prior to the bankruptcy filing in January of 2019. In
this regard, we note
         from your disclosure on page 62 that you recorded other-than-temporary
impairment
         losses of $15 million in fiscal 2018. Please clarify whether these
losses were recorded in
         connection with your investments in either Agua Caliente or Ivanpah.
If the losses are
         related to these investments, then explain to us why you believe the
remaining carrying
         value of these investments is recoverable as of December 31, 2018. If
the losses are not
         related to these investments, then explain to us how you considered
the guidance in ASC
         323-10-35-32 in determining that your Agua Caliente and Ivanpah equity
method
         investments were not other than temporarily impaired as of December
31, 2018. Please
         ensure that your response addresses the specific factors that you
considered to support the
         recoverability of these equity method investments as of December 31,
2018 and your
         related accounting.
Variable Interest Entities, page 165

2.       We note your disclosure regarding certain events related to Ivanpah
which were
         considered to be a reconsideration event in accordance with ASC 810.
Please summarize
         for us the circumstances surrounding the reconsideration event and
provide us with your
         accounting analysis which led to you conclude you were not the primary
beneficiary of
         Ivanpah.
Form 10-Q for the Quarterly Period Ended March 31, 2019

Note 16 - Commitments and Contingencies
Contingencies, page 36

3.       Please refer to your disclosure related to the Midwest Generation
Asbestos Liabilities.
         We note the parties have agreed to the terms of a settlement that will
resolve all of
         ComEd's outstanding claims in this matter. Based on your O&M results
discussion on
         page 64 it appears you previously accrued for this matter. Please
clarify for us how you
         considered the disclosures required by ASC 450-20-50-1.
        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.
 Kirkland Andrews
NRG Energy, Inc.
June 25, 2019
Page 3

        You may contact Robert Babula, Staff Accountant at (202) 551-3339, or
Donna Di
Silvio, Staff Accountant at (202) 551-3202 if you have questions regarding
comments on the
financial statements and related matters.



FirstName LastNameKirkland Andrews                        Sincerely,
Comapany NameNRG Energy, Inc.
                                                          Division of
Corporation Finance
June 25, 2019 Page 3                                      Office of Consumer
Products
FirstName LastName