Royal Dutch Shell plc
Carel van Bylandtlaan 30
2596 HR The Hague
The Netherlands
Tel +31 70 377 3120
Email Martin.J.tenBrink@shell.com
Internet http://www.shell.com
Mr. Brad Skinner
Senior Assistant Chief Accountant
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-4628
United States of America
FOIA: Rule 83 Confidential Treatment Requested
November 10, 2014
| RE: | Royal Dutch Shell plc |
Form 20-F for Fiscal Year Ended December 31, 2013
Filed March 13, 2014
File No.1-32575
SEC letter September 9, 2014
Dear Mr. Skinner,
As Controller of Royal Dutch Shell plc (“Royal Dutch Shell”), and on behalf of Royal Dutch Shell and its subsidiaries, I am responding to your letter of October 23, 2014, to Ben van Beurden regarding the Royal Dutch Shell Form 20-F for the Fiscal Year Ended December 31, 2013. Capitalized terms used but not defined herein have the same meaning given to such terms as in the Royal Dutch Shell Form 20-F for the Fiscal Year Ended December 31, 2013, filed March 13, 2014 (Commission File Number 1-32575). Please see below our numbered responses to your comments.
Form 20-F for the Fiscal Year Ended December 31, 2013
Upstream, page 23
Proved Undeveloped Reserves, page 25
| 1. | In part, comment 1 in our September 9, 2014 letter requested that you “ . . . expand this disclosure to identify all items that materially impacted proved undeveloped reserves during the year. For example sources of change, see FASB ASC paragraph 932-235-50-5: See also Item 1203(b) of Regulation S-K.” Your response addressed your intent “In future Form 20-F filings, we will include the amount of proved undeveloped reserves that as a result of project execution moved to proved developed reserves during the year.” Please explain to us all the separate sources of material change to your PUD reserves during 2013 and affirm to us that you will disclose such items for the latest year ended in future filings. |
Registered in England and Wales number 4366849
Registered office: Shell Centre London SE1 7NA
Registered with the Dutch Trade Register under number 34179503
Mr. Brad Skinner
Securities and Exchange Commission
Rule 83 Confidential Treatment Requested
November 10, 2014
Page 2 of 2
The most significant changes in our proved undeveloped reserves occurred in Canada with the addition of 435 million boe as a result of improved recovery in our Peace River thermal project; in the United States with the addition of 129 million boe as a result of extension and discoveries; and in Oceania with the addition of 83 million boe associated with positive revisions. In future Form 20-F filings we will disclose all sources of material changes in proved undeveloped reserves, including the amount of proved undeveloped reserves that as a result of project execution moved to proved developed reserves during the year.
| 2. | Our comment 3 requested that you “For your share of the Kashagan project, please explain to us your proved developed reserves, proved undeveloped reserves, projected production resumption date, sunk capital costs, remaining projected capital costs and fees to be assessed by the host government for project delays.” As it appears your response omitted figures for your share of Kashagan proved undeveloped reserves and fees to be assessed by the Kazakh government, we reissue our prior comment 3. |
Rule 83 Confidential Treatment Requested for Bracketed Information
[ ]
If you have any questions please contact me at +31 70 377 3120 or Joseph Babits at +1 713 241 3564 (Joseph.Babits@shell.com).
Sincerely,
/s/ Martin J. ten Brink
Martin J. ten Brink
Executive Vice President Controller
| Cc: | Mark Wojciechowski |
Division of Corporation Finance
Securities and Exchange Commission
Ronald Winfrey
Petroleum Engineer
Securities and Exchange Commission