January 31, 2012
VIA OVERNIGHT DELIVERY
H. Roger Schwall
Assistant Director
Division of Corporate Finance
U. S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
RE: Energen Corporation and Alabama Gas Corporation
Form 10-K for Fiscal Year Ended December 31, 2010
Filed February 25, 2011
File No. 001-07810
Dear Mr. Schwall:
Energen Corporation has received your letter to our Chief Executive Officer, James McManus, dated January 30, 2012. We have reviewed your comments and submit the following response for your consideration:
Engineering Comments
Form 10-K for Fiscal Year Ended December 31, 2010
Properties, page 13
Proven Undeveloped Reserves, Bcfe, page 14
1. We note your presentation of the line item “Extensions, discoveries and acquisitions” in the reconciliation of changes for your year-end 2010 PUD reserves. Please expand this so that the acquisitions are disclosed separately from extensions and discoveries. Refer to Item 1203(b) of Regulation S-K and FASB ASC 932-235-50-5.
In future filings the Company will expand its disclosure to state acquisitions separately from extensions and discoveries.
H, Roger Schwall
January 31, 2012
Page 2
Please call me if you need additional information or clarification.
Sincerely, |
/s/ J. David Woodruff |
J. David Woodruff General Counsel and Secretary |