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Mail Stop 4628
September 20, 2018
Ben van Beurden
Chief Executive Officer
Royal Dutch Shell plc
Carel van Bylandtlaan 30
The Hague, The Netherlands, 2596 HR
Re: Royal Dutch Shell plc
Form 20-F for the Fiscal Year Ended December 31, 2017
Filed March 15, 2018
File No. 1-32575
Dear Mr. van Beurden:
We have limited our review of your filing to the financial statements
and related
disclosures 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 20-F for the Fiscal Year Ended December 31, 2017
Oil and Gas Information, page 38
Proved Undeveloped Reserves, page 39
1. Your discussion of the changes in proved undeveloped reserves is focused
on physical
locations and describes factors that "mainly" contributed to changes in
proved
undeveloped reserves in those areas. As a result, it is not clear that
the discussion
addresses all material changes in proved undeveloped reserves that
occurred during the
year. For example, the only revision addressed in your disclosure is the
negative revision
of compression volumes at Gronigen. However, disclosure on page 38
appears to suggest
that higher SEC prices as of December 31, 2017 had a material impact on
your proved
undeveloped reserves as compared to December 31, 2016. Explain to us how
your
current presentation addresses the disclosure requirements of Item
1203(b) of Regulation
S-K. As part of your response, provide us with an analysis that
reconciles your beginning
Ben van Beurden
Royal Dutch Shell plc
September 20, 2018
Page 2
and ending proved undeveloped reserves for 2017 that shows all material
changes by type
of change.
2. Disclosure on page 39 indicates that "1,566 million boe PUD volumes were
matured to
PD. This included 297 million boe that were matured to PD from
contingent resources
through PUD as a result of project execution during the year." Expand
this disclosure to
reconcile the net difference of 1,269 million boe to the 519 million boe
attributed to
maturation in your discussion of changes in proved undeveloped reserves
appearing
elsewhere on this page.
Supplementary Information Oil and Gas, page 179
Crude Oil, Natural Gas Liquids, Synthetic Crude Oil and Bitumen, page 180
3. Your discussion of changes in proved reserves indicates, in various
places, that revisions
and reclassifications resulted from "field performance studies and
development
activities." Expand your disclosure to more clearly explain what this is
intended to
convey, including whether this represents one factor or two. To the
extent that this
represents two factors, explain to us how you considered quantifying the
amount
attributable to each factor. See FASB ASC 932-235-50-5. Note that this
comment also
applies to similar discussion of changes in natural gas volumes
appearing on page 184.
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 Mark Wojciechowski, Staff Accountant, at (202) 551-3759,
or me at
(202) 551-3489 with any questions.
Sincerely,
/s/ Brad Skinner
Brad Skinner
Senior Assistant
Chief Accountant
Office of Natural
Resources