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                             August 17, 2021

       Jason McGlynn
       Senior Vice President and Chief Financial Officer
       Amplify Energy Corporation
       500 Dallas Street, Suite 1700
       Houston, Texas 77002

                                                        Re: Amplify Energy
Corporation
                                                            Form 10-K for the
Fiscal Year ended December 31, 2020
                                                            Filed March 11,
2021
                                                            File No. 001-35512

       Dear Mr. McGlynn:

              We have reviewed your filing 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 10-K for the Fiscal Year ended December 31, 2020

       Business
       Our Oil and Natural Gas Data
       Development of Proved Undeveloped Reserves, page 15

   1.                                                   Please expand the
discussion of the changes in the net quantities of your proved
                                                        undeveloped reserves to
clearly identify the source of each change, e.g. revisions,
                                                        improved recovery,
extensions and discoveries, transfers to proved developed, sales and
                                                        acquisitions, and to
include an explanation relating to each of the items you identify. If
                                                        two or more unrelated
factors are combined to arrive at the overall change for an item, you
                                                        should separately
identify and quantify each material factor so that the change in net
                                                        reserve quantities
between periods is fully explained.

                                                        The disclosure of
revisions in previous estimates of your proved undeveloped reserves in
                                                        particular should
identify the changes associated with individual factors, such as changes
 Jason McGlynn
FirstName LastNameJason   McGlynn
Amplify Energy  Corporation
Comapany
August 17, NameAmplify
           2021          Energy Corporation
August
Page 2 17, 2021 Page 2
FirstName LastName
         caused by commodity prices, costs, royalty adjustments, well
performance, unsuccessful
         and/or uneconomic proved undeveloped locations, or the removal of
proved undeveloped
         locations due to changes in a previously adopted development plan. You
may refer to
         Item 1203(b) of Regulation S-K if you require further clarification or
guidance.

         Please similarly revise your disclosures of changes in the net
quantities of total proved
         reserves on page F-41, to address for each period the changes depicted
in each line item in
         the reconciliation, other than production, to comply with FASB ASC
932-235-50-5.
2.       We note your disclosure indicating that none of the 17.2 MMBoe in
proved undeveloped
         reserves as of December 31, 2020 are scheduled to be developed on a
date more than five
         years from the date these reserves were initially disclosed. However,
you also indicate that
         during the twelve months ending December 31, 2020, you converted
approximately 0.1
         MMBoe or approximately 0.4% of the proved undeveloped reserves as of
December 31,
         2019. That rate of conversion suggests that you may not be able to
develop your proved
         undeveloped reserves within five years of initial disclosure.

         Please provide us with your development schedule, indicating for each
future annual
         period, the number of gross wells to be drilled, the associated net
quantities of reserves,
         and estimated capital expenditures necessary to convert such reserves
to developed
         reserves, to include all of the proved undeveloped reserves disclosed
as of December 31,
         2020, and describe any change made or expected to be made in the
schedule that would
         deviate from the definition set forth in Rule 4-10(a)(31)(ii) of
Regulation S-X.
3.       Tell us the extent to which all of the undeveloped locations in the
development schedule
         requested in the preceding comment are part of a development plan that
is reviewed
         annually and adopted by management, including approval by the Board,
if such approval
         is required. Refer to Rule 4-10(a)(31)(ii) of Regulation S-X and the
Question 131.04 in
         the Compliance and Disclosure Interpretations (C&DIs).
Undeveloped Acreage, page 17

4.       You disclose that 3,849 net undeveloped acres or approximately 60% of
the total 6,456
         net undeveloped acres in Oklahoma are subject to lease expiration by
the end of 2021.
         Please tell us the extent to which you have assigned any proved
undeveloped reserves to
         locations which are currently scheduled to be drilled after lease
expiration.

         If there are material quantities of net proved undeveloped reserves
relating to such
         locations, expand the disclosure here or in an appropriate section
elsewhere in your filing
         to describe the uncertainty in reasonable detail, including the steps
and related costs that
         would be necessary to extend the time to the expiration of such
leases, considering the
         guidance in Rule 4-10(a)(26) of Regulation S-X and FASB ASC
932-235-50-10.
 Jason McGlynn
Amplify Energy Corporation
August 17, 2021
Page 3
Exhibits and Financial Statement Schedules
Exhibit Number 99.1 Report of Cawley, Gillespie and Associates, Inc., page 68

5.       The reserves report includes among its results of the evaluation line
items entitled
         Miscellaneous Expenses 1, Miscellaneous Expenses 2, Other Deductions,
and
         Investments. Please tell us the types of costs represented by each
line item shown in the
         results of the evaluation table. You should also obtain and file a
revised reserves report
         that describes this information as part of the primary economic
assumptions that are
         required to be disclosed pursuant to Item 1202(a)(8)(v) of Regulation
S-K.
Financial Statements
Note 18 - Supplemental Oil and Gas Information (Unaudited), page F-39

6.       We note your disclosure on page F-41 indicating that future costs used
in calculating the
         standardized measure as of December 31, 2020 include the abandonment
costs for your
         onshore and offshore properties.

         Please tell us if such abandonment costs include all of the costs
relating to your properties
         located in federal waters offshore Southern California that are
expected to be incurred in
         connection with the removal of all fixed drilling equipment,
production facilities and the
         related offshore platforms and pipelines, and the plugging and
abandonment of all wells,
         active and inactive, and all reclamation and restoration associated
with abandonment.

         Please submit a schedule quantifying the abandonment costs associated
with each of these
         activities that are reflected in your standardized measure and if
applicable any incremental
         costs that have been excluded in calculating your standardized
measure. If any such costs
         have been excluded, please explain your rationale and describe any
disclosures that you
         would propose, considering the guidance in FASB ASC 932-235-50-36.
        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 John Hodgin, Petroleum Engineer, at (202) 551-3699 if
you have
questions regarding the comments. Please contact Karl Hiller, Branch Chief, at
(202) 551-3686
with any other questions.



FirstName LastNameJason McGlynn                                 Sincerely,
Comapany NameAmplify Energy Corporation
                                                                Division of
Corporation Finance
August 17, 2021 Page 3                                          Office of
Energy & Transportation
FirstName LastName