July 15, 2019
Jennifer R. Kneale
Chief Financial Officer
Targa Resources Corp.
811 Louisiana St.
Suite 2100
Houston, TX 77002
Re: Targa Resources Corp.
Form 10-K for the Year Ended December 31, 2018
Response Dated June 7, 2019
File No. 001-34991
Targa Resources Partners LP
Form 10-K for the Year Ended December 31, 2018
Response Dated June 7, 2019
File No. 001-33303
Dear Ms. Kneale:
We have reviewed your June 7, 2019 response to our comment letter and
have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.
Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your
response.
After reviewing your response to this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
May 23, 2019 letter.
Supplemental Response Filed June 7, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Our Non-GAAP Financial Measures, page 63
1. We have reviewed your response to comment 2. Please revise this measure
in all future
filings to exclude the adjustment for the "Splitter Agreement" presented
in your Adjusted
EBITDA measure. The measure as presented does not conform to Question
100.04 of the
Non-GAAP Compliance & Disclosure Interpretations.
Jennifer R. Kneale
Targa Resources Corp.
July 15, 2019
Page 2
You may contact Yong Kim, Staff Accountant, at (202) 551-3323 or James
Allegretto,
Senior Assistant Chief Accountant, at (202) 551-3849 with any questions.
FirstName LastNameJennifer R. Kneale Sincerely,
Comapany NameTarga Resources Corp.
Division of Corporation
Finance
July 15, 2019 Page 2 Office of Consumer
Products
FirstName LastName