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United States securities and exchange commission logo
September 14, 2022
W. Bryan Buckler
Chief Financial Officer
OGE Energy Corp.
321 North Harvey
P.O. Box 321
Oklahoma City, Oklahoma 73101-0321
Re: OGE Energy Corp.
Form 10-K for
Fiscal Year Ended December 31, 2021
Filed February 24,
2022
File No. 001-12579
Dear Mr. Buckler:
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, 2021
General
1. We note that you
provided more expansive disclosure in your 2021 Climate Analysis than
you provided in your
SEC filings. Please advise us what consideration you gave to
providing the same type
of climate-related disclosure in your SEC filings as you provided
in your 2021 Climate
Analysis.
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
27
2. Revise your disclosure
to identify any past and/or future capital expenditures for climate-
related projects.
Please provide quantitative information for each of the periods for which
financial statements
are presented in your Form 10-K and for any future periods as part of
your response.
W. Bryan Buckler
OGE Energy Corp.
September 14, 2022
Page 2
3. To the extent material, discuss in greater detail the indirect
consequences of climate-
related regulation or business trends, such as decreased demand for
services that produce
significant greenhouse gas emissions or are related to carbon-based
energy sources.
4. We note your disclosure regarding the physical effects of climate change
on your
operations and results. If material, please revise your disclosure to
include the following:
quantification of material weather-related damages to your property
or operations;
potential for indirect weather-related impacts that have affected or
may affect your
major customers; and
any weather-related impacts on the cost or availability of insurance.
Your response should include quantitative information for each of the
periods for which
financial statements are presented in your Form 10-K and explain whether
changes are
expected in future periods.
5. Please tell us about and quantify compliance costs related to climate
change for each of
the periods covered by your Form 10-K and whether increased amounts are
expected to be
incurred in future periods.
6. Please tell us about and quantify any purchase or sale of carbon credits
or offsets during
the last three years and any planned future period transactions.
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 Michael Purcell at 202-551-5351 or Karina Dorin at
202-551-3763 with
any questions.
Sincerely,
FirstName LastNameW. Bryan Buckler
Division of
Corporation Finance
Comapany NameOGE Energy Corp.
Office of Energy &
Transportation
September 14, 2022 Page 2
cc: William Sultemeier
FirstName LastName