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                             April 25, 2023

       Jeff Holman
       Chief Financial Officer
       Magellan Midstream Partners, L.P.
       One Williams Center
       P.O. Box 22186
       Tulsa, OK 74121-2186

                                                        Re: Magellan Midstream
Partners, L.P.
                                                            Form 10-K for the
Fiscal Year ended December 31, 2022
                                                            Filed February 21,
2023
                                                            File No. 001-16335

       Dear Jeff Holman:

              We have reviewed your April 10, 2023 response to our comment
letter and have the
       following comment. In some of our comments, we may ask you to provide us
with information
       so we may better understand your disclosure.

              Please respond to this comment 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
       comment applies to your facts and circumstances, please tell us why in
your response.

             After reviewing your response to this comment, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       March 16, 2023 letter.

       Form 10-K for the Fiscal Year ended December 31, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations, page 40

   1.                                                   We understand from page
5 of your response to our prior comments that you regard
                                                        operating profit as the
most directly comparable GAAP measure to your non-GAAP
                                                        measure of operating
margin because there would be two rather than five reconciling
                                                        adjustments, when
compared to a GAAP measure of gross margin.

                                                        However, your
assessment appears to be based on a comparison of gross margin for
                                                        product sales alone,
e.g. excluding transportation and terminals revenue and associated
                                                        costs of revenue,
rather than gross margin for the consolidated results of operations.
 Jeff Holman
Magellan Midstream Partners, L.P.
April 25, 2023
Page 2

         Please revisit your assessment to utilize gross margin for the
consolidated results of
         operations, which we generally regard as the most directly comparable
GAAP measure to
         utilize when presenting a non-GAAP margin measure.

         Given the similarity of your operating margin label to GAAP
terminology, please also
         select an alternate label that more clearly reflects its character as
a non-GAAP measure, to
         use when referring to the measure in MD&A, segment disclosures, and
earnings releases,
         to comply with Item 10(e)(1)(ii)(E) of Regulation S-K.

         As your non-GAAP operating margin presently appears in advance of the
measure that
         you believe is the most directly comparable GAAP measure in your
reconciliation on page
         40, revisions will also be necessary to follow the guidance in the
answer to Question
         102.10(b) of our Compliance & Disclosure Interpretations on Non-GAAP
Financial
         Measures, to avoid giving undue prominence to your non-GAAP measure of
operating
         margin. However, as indicated above you may need to utilize
consolidated gross margin
         as the most directly comparable GAAP measure in the reconciliation.

         We suggest that you reposition the non-GAAP measure and reconciliation
to a separate
         tabulation, to follow the GAAP information shown on page 40. Please
submit the
         revisions that you propose to address the concerns outlined above
regarding the labeling
         and reconciliation for your non-GAAP measure of operating margin.

       You may contact Sondra Snyder, Staff Accountant at (202) 551-3332 or
Robert Babula,
Staff Accountant at (202) 551-3339 with any questions.



FirstName LastNameJeff Holman                                  Sincerely,
Comapany NameMagellan Midstream Partners, L.P.
                                                               Division of
Corporation Finance
April 25, 2023 Page 2                                          Office of Energy
& Transportation
FirstName LastName