September 13, 2019

A. Wade Pursell
Chief Financial Officer
SM Energy Company
1775 Sherman Street, Suite 1200
Denver, Colorado 80203

       Re: SM Energy Company
           Form 10-K for Fiscal Year Ended December 31, 2018
           Filed February 21, 2019
           File No. 001-31539

Dear Mr. Pursell:

       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 10-K for Fiscal Year Ended December 31, 2018

Reserves
Proved Undeveloped Reserves, page 9

1.    You state in your Form 10-K that you reduced capital investment in the
Eagle Ford during
      2018 and that the majority of capital will be spent elsewhere in 2019
(i.e., approximately
      80% of your 2019 capital will be allocated to the Midland Basin).
Separately, comments
      attributed to your CEO as part of the earnings call regarding your
results for the period
      ended June 30, 2019 suggest that capital activity will be shifted away
from your
      operations in the Eagle Ford if commodity prices do not improve. Provide
us with
      supplemental information showing the progress made in developing your
proved
      undeveloped reserves ("PUDs") in the Eagle Ford, both during the fiscal
year ended
      December 31, 2018 and the interim period ended June 30, 2019, along with
a discussion
      of any delays in development that occurred during these periods. In
addition, explain how
      decisions to reduce capital investment affected your reported quantities
of PUDs in the
 A. Wade Pursell
SM Energy Company
September 13, 2019
Page 2
         Eagle Ford. Refer to Item 1203(c) of Regulation S-K and Rule
4-10(a)(22) of Regulation
         S-X.
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Overview of the Company
2018 Financial and Operational Highlights
Operational Activities, page 45

2.       We note that you had 23 and 20 net wells drilled but not completed as
of December 31,
         2018 and June 30, 2019, respectively, in your South Texas & Gulf Coast
region. In light
         of the statement in your Form 8-K dated July 18, 2019 that you plan
"to wrap-up 2019
         planned net completions" in South Texas in the quarter ended September
30, 2019, tell us
         the expected number of net wells drilled but not completed as of
September 30, 2019 and
         quantify the associated PUDs. As part of your response, address your
plans for any wells
         drilled but not completed as of December 31, 2018 remaining at
September 30, 2019.
        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 Jeannette Wong, Staff Accountant, at (202) 551-2137 if
you have
questions regarding comments on the financial statements and related matters.
Please contact
Ethan Horowitz, Accounting Branch Chief, at (202) 551-3311 with any other
questions.



FirstName LastNameA. Wade Pursell                            Sincerely,
Comapany NameSM Energy Company
                                                             Division of
Corporation Finance
September 13, 2019 Page 2                                    Office of Natural
Resources
FirstName LastName