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United States securities and exchange commission logo
December 17, 2021
Jennifer R. Kneale
Chief Financial Officer
Targa Resources Corp.
811 Louisiana St., Suite 2100
Houston, Texas 77002
Re: Targa Resources
Corp.
Form 10-K for
Fiscal Year Ended December 31, 2020
Response dated
December 10, 2021
File No. 001-34991
Dear Ms. Kneale:
We have reviewed your December 10, 2021 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
November 29, 2021 letter.
Form 10-K for Fiscal Year Ended December 31, 2020
Management's Discussion and Analysis of Financial Condition and Results
of Operations
Non-GAAP Measures, page 62
1. We note your response
to prior comment 1. Tell us how you concluded that the non-
GAAP measure segment
adjusted gross margin is appropriately named considering that
you believe segment
operating margin is the most directly comparable GAAP-basis
measure.
Jennifer R. Kneale
Targa Resources Corp.
December 17, 2021
Page 2
You may contact Jennifer O'Brien, Staff Accountant, at 202-551-3721 or
Kimberly
Calder, Assistant Chief Accountant, at 202-551-3701 if you have any questions.
FirstName LastNameJennifer R. Kneale Sincerely,
Comapany NameTarga Resources Corp.
Division of
Corporation Finance
December 17, 2021 Page 2 Office of Energy &
Transportation
FirstName LastName