United States securities and exchange commission logo





                              August 28, 2020

       Rodney D. Gray
       Executive Vice President and Chief Financial Officer
       Baytex Energy Corporation
       2800, 520 - 3rd Avenue S.W.
       Calgary, Alberta T2P 0R3

                                                        Re: Baytex Energy
Corporation
                                                            Form 40-F for the
Fiscal Year ended December 31, 2019
                                                            Filed March 10,
2020
                                                            File No. 001-32754

       Dear Mr. Gray:

              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 40-F for the Fiscal Year ended December 31, 2019

       Exhibit 99.10
       Supplemental Disclosures about Extractive Activities-Oil and Gas
(Unaudited)
       Petroleum and Natural Gas Reserves Information, page 1

   1.                                                   Please revise your
disclosure of crude oil and NGL reserves to separately disclose the net
                                                        quantities of NGL
reserves to comply with FASB ASC 932-235-50-4. This comment also
                                                        applies to the figures
used in the reconciliation showing the changes that occurred in total
                                                        proved reserves, and to
your disclosure of the net quantities of proved developed and
                                                        proved undeveloped
reserves, for each period.
   2.                                                   Please clarify the
extent to which the figures reported as natural gas reserves and
                                                        production volumes
include flared gas, injected gas, and gas consumed in operations to
                                                        comply with FASB ASC
932-235-50-10.
 Rodney D. Gray
Baytex Energy Corporation
August 28, 2020
Page 2
3.       Please expand your disclosure to separately present the net quantities
of your proved
         undeveloped reserves by individual product type as of the beginning
and end of each
         period presented to comply with FASB ASC 932-235-50-4.
4.       Tell us the extent to which the undrilled locations underlying your
estimates of proved
         undeveloped reserves as of December 31, 2018 and 2019 are included in
a development
         plan that has been adopted and that indicates these locations are
scheduled to be drilled
         within five years of the initial development plan adoption date.

         For any locations that do not satisfy this criteria, please describe
any specific
         circumstances that you believe justify a longer period of time. You
may refer to the
         definition of    Proved Undeveloped Oil and Gas Reserves    in the
Glossary of FASB ASC
         932-235-20 if you require further clarification.
5.       Please expand your disclosure to explain the reasons for significant
changes in the net
         quantities of total proved reserves for each line in the reserves
reconciliation, other than
         production, for each period to comply with FASB ASC 932-235-50-5.
Standardized Measure of Discounted Future Net Cash Flows Relating to Proved
Petroleum and
Natural Gas Reserves, page 2

6.       Tell us the extent to which all estimated future costs to settle your
asset retirement
         obligations have been included in your calculation of the standardized
measure for each
         period, and if any such costs have been omitted, please explain to us
your rationale.
        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 comments. Please contact Karl Hiller, Branch Chief, at
(202) 551-3686
with any other questions.



FirstName LastNameRodney D. Gray                                Sincerely,
Comapany NameBaytex Energy Corporation
                                                                Division of
Corporation Finance
August 28, 2020 Page 2                                          Office of
Energy & Transportation
FirstName LastName