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                             July 13, 2022

       Herbert S. Vogel
       President and Chief Executive Officer
       SM Energy Company
       1775 Sherman Street, Suite 1200
       Denver, CO 80203

                                                        Re: SM Energy Company
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed February 25,
2022
                                                            Form 8-K, Filed
February 24, 2022
                                                            File No. 001-31539

       Dear Mr. Vogel:

              We have limited our review of your filings to the financial
statements and related
       disclosures 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, 2021

       Business and Properties
       Reserves
       Proved Undeveloped Reserves, page 13

   1.                                                   Please expand your
discussion of the changes that occurred in your proved undeveloped
                                                        reserves relating to
extensions, discoveries and infill development, and revisions of the
                                                        previous estimates to
separately identify and quantify each material factor, including
                                                        offsetting factors,
that contributed to the change to comply with Item 1203(b) of
                                                        Regulation S-K.

                                                        The disclosure of
revisions in previous estimates of your proved undeveloped reserves
                                                        in particular should
identify the changes associated with individual factors, such as
                                                        changes caused by
commodity prices, costs, interest adjustments, well performance,
 Herbert S. Vogel
FirstName
SM EnergyLastNameHerbert S. Vogel
            Company
Comapany
July       NameSM Energy Company
     13, 2022
July 13,
Page  2 2022 Page 2
FirstName LastName
         unsuccessful and/or uneconomic proved undeveloped locations.

         Your disclosure should clearly identify the source of the change and
include an
         explanation relating to each of the items you identify. If two or more
unrelated factors are
         combined to arrive at the overall change for an item, please
separately identify and
         quantify each material factor so that the change in net reserve
quantities between periods
         is fully explained.
Notes to Consolidated Financial Statements
Supplemental Oil and Gas Information (Unaudited)
Standardized Measure of Discounted Future Net Cash Flows, page 99

2.       Please expand the presentation of the standardized measure to clarify,
if true, that future
         cash flows take into account the estimated abandonment costs for the
proved properties to
         comply with FASB ASC 932-235-50-36.

         If the abandonment costs, including such costs related to proved
undeveloped locations,
         have not been included for each of the periods presented, e.g. as of
December 31, 2021,
         2020 and 2019, please explain to us the rationale for excluding these
costs from the
         calculation of the standardized measure.
Form 8-K, Filed February 24, 2022

Exhibit 99.1
Adjusted Operating Margin Reconciliation, page 20

3.       We note you identified Adjusted operating margin (before the effects
of derivative
         settlements) and Adjusted operating margin (including the effect of
derivative settlements)
         as non-GAAP measures and reconciled these measures to your oil, gas
and NGL revenues
         and also to income (loss) from operations for the three months ended
December 31, 2021
         and December 31, 2020. Please tell us how you considered reconciling
these measures to
         the most directly comparable GAAP measure, fully-loaded GAAP gross
margin. Refer to
         Item 10(e)(1)(i)(B) of Regulation S-K.
       In closing, 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.
 Herbert S. Vogel
SM Energy Company
July 13, 2022
Page 3

        You may contact Sandra Wall, Petroleum Engineer, at (202) 551-4727, or
John
Hodgin, Petroleum Engineer, at (202) 551-3699 on engineering matters. Please
contact Sondra
Snyder, Senior Staff Accountant, at (202) 551-3332 or Gus Rodriguez, Accounting
Branch
Chief, at (202) 551-3752 with any other questions.



FirstName LastNameHerbert S. Vogel                       Sincerely,
Comapany NameSM Energy Company
                                                         Division of
Corporation Finance
July 13, 2022 Page 3                                     Office of Energy &
Transportation
FirstName LastName