View:
United States securities and exchange commission logo
September 1, 2022
Kirkland B. Andrews
Chief Financial Officer
Evergy, Inc.
1200 Main Street
Kansas City, Missouri 64105
Re: Evergy, Inc.
Form 10-K for the
Fiscal Year ended December 31, 2021
Filed February 25,
2022
Response Letter
dated August 5, 2022
File No. 001-38515
Dear Mr. Andrews:
We have reviewed your August 5, 2022 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
July 22, 2022 letter.
Form 10-K for the Fiscal Year ended December 31, 2021
Management's Discussion and Analysis
Executive Summary
Non-GAAP Measures, page 38
1. We have read your
response to prior comment one, including the incremental disclosures
that you have proposed
to include in future filings that include your non-GAAP utility
margin. Please expand
such disclosures to address the following additional points.
Provide further
details in footnote (a) to the reconciliation of the nature of operating
and maintenance
expenses that are deemed to be directly attributable to your revenue-
producing
activities (i.e. cost of sales), and to clarify how these are differentiated
Kirkland B. Andrews
Evergy, Inc.
September 1, 2022
Page 2
from other costs reported in this line item on page 72.
Provide quantification of the various factors underlying
changes in the measures of
GAAP gross margin in the narrative which follows the
reconciliation, comparable to
your discussion and analysis of changes in non-GAAP utility gross
margin.
You may contact Lily Dang at (202) 551-3867 or Mark Wojciechowski at
(202) 551-
3759 if you have questions regarding comments on the financial statements and
related
matters. Please contact Karl Hiller - Branch Chief at (202) 551-3686 with any
other questions.
FirstName LastNameKirkland B. Andrews Sincerely,
Comapany NameEvergy, Inc.
Division of
Corporation Finance
September 1, 2022 Page 2 Office of
Energy & Transportation
FirstName LastName