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1.

We note your response to comment 1 in our letter dated September 11, 2015. You state that operation and maintenance expense presented on your statements of income represents the cost of your service revenue and that you will add a footnote disclosing this along with a statement that any operation and maintenance expenses associated with product sales are immaterial. On page 59 you disclose that operation and maintenance expenses consist primarily of labor expenses, lease costs, utility costs, insurance premiums and repairs and maintenance expenses. It appears that the types of expenses included in operation and maintenance expenses would be incurred in connection with producing both service revenues and product revenues. In addition, it appears that for product sales you would incur further labor costs for marketing and selling such products. Please tell us in more detail how you determined that the portion of operation and maintenance costs attributable to product revenues was immaterial. Also tell us how you considered whether your operation and maintenance expenses include any costs contemplated by Rule 5-03.3, 5-03.4, 5-03.5 or 5-03.6 of Regulation S-X when concluding you should disclose that operation and maintenance expense represents the cost of your service revenue as contemplated by Rule 5-03.2 of Regulation S-X.

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Rule 5-03.3 provides that for other operating costs and expenses, any material amounts not included as costs and expenses applicable to sales and revenue under Rule 5-03.2 of Regulation S-X should be separately stated. There are no material amounts that have been excluded from costs and expenses applicable to sales and revenue, and, therefore, no separate statement of material amounts of other operating costs and expenses is required. All material costs and expenses applicable to sales and revenues are included under “Costs and Expenses” in our statements of income as follows: (i) cost of tangible goods sold are included in “Cost of natural gas and natural gas liquids”; (ii) cost of services are included in “Operation and maintenance”; and (iii) other operating expenses are included in “Depreciation and amortization” and “Taxes other than income taxes.”

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Rule 5-03.4 contemplates selling, general and administrative expenses. We have historically considered these types of expenses to be incurred in connection with producing both service revenues and product revenues, associated with providing midstream services. Therefore, we have historically included these expenses in “Operation and maintenance” as a cost of service under “Costs and Expenses” in our statements of income. As a result, selling, general and administrative expenses were not separately presented under “Costs and Expenses” in our statements of income. For the years ended December 31, 2014 and 2013, these types of expenses amounted to approximately $107 million and $71 million, respectively. For the years ended December 31, 2014 and 2013, our “Operation and maintenance” expenses were $527 million and $429 million, respectively. Therefore, for the years ended December 31, 2014 and 2013, the portion of selling, general and administrative

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Rule 5-03.5 contemplates provision for doubtful accounts and notes. These expenses are included in “Operations and maintenance” under “Costs and Expenses” in our statements of income. Provision for doubtful accounts and notes is discussed in “Accounts Receivable and Allowance for Doubtful Accounts” included in Note 1 of the Notes to the Audited Combined and Consolidated Financial Statements in our Form 10-K for Fiscal Year Ended December 31, 2014. For the years ended December 31, 2014 and 2013, these expenses with were less than $0.1 million for the respective periods. For the years ended December 31, 2014 and 2013, our cost of natural gas and natural gas liquids were $1,914 million and $1,313 million, respectively. Therefore, for the years ended December 31, 2014 and 2013, provision for doubtful accounts and notes is less than 1% of the expenses in “Operations and maintenance” for the respective periods. As these expenses are immaterial, we have not separately stated provision for doubtful accounts and notes under “Costs and Expenses” in our statements of income.

•	Rule 5-03.6 provides that any material items not normally included under 5-03.4 should be separately stated. For the years ended December 31, 2014 and 2013, there are no material items not normally included under 5-03.4. Therefore, no separate statement of material items not normally included under 5-03.4 is required.

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