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                               September 25, 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 September 14, 2020 response to our comment
letter 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. Unless we note otherwise, our references to prior comments are
to comments in our
       August 28, 2020 letter.

       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.                                                   We understand from your
response to our prior comment letter that you will provide
                                                        disclosures beginning
with your next annual report on Form 40-F, consistent with the
                                                        revisions outlined in
your response letter. Please also incorporate the revisions that are
                                                        necessary to address
the concerns outlined in the remaining comment in this letter.
   2.                                                   We note that your
response to prior comment five, regarding the reasons for significant
                                                        changes in total proved
reserves, indicates that the change attributed to improved recovery
                                                        for fiscal 2018 was the
result of infill drilling.
 Rodney D. Gray
Baytex Energy Corporation
September 25, 2020
Page 2
         However, we believe that changes associated with infill drilling
should be categorized as
         revisions of previous estimates, rather than improved recovery, based
on the guidance in
         subparagraphs (a) and (b) of FASB ASC 932-235-50-5.

         Under this guidance, improved recovery relates to the recovery of
hydrocarbons, beyond
         primary recovery, obtained through secondary or tertiary recovery
methods that generally
         supplement the natural reservoir recovery processes. Please revise the
classifications
         within your reserves reconciliations and the associated narratives
accordingly.
       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
September 25, 2020 Page 2                                     Office of Energy
& Transportation
FirstName LastName