November 26, 2019

Corey D. Code
Chief Financial Officer
1847432 Alberta ULC
Suite 4400, 500 Centre Street S.E., P.O. Box 2850
Calgary, Alberta, Canada, T2P 2S5

       Re: 1847432 Alberta ULC
           Registration Statement on Form S-4
           Filed November 6, 2019
           File No. 333-234526

Dear Mr. Code:

       We have limited our review of your registration statement to those
issues we have
addressed in our 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments.

Registration Statement on Form S-4 filed November 6, 2019

General

1.     Please provide an analysis with respect to why you are not required to
present as separate
       proposals each provision of Ovintiv's charter and bylaws that differ in
material respects
       from Encana's governing documents. For example, we note various
provisions of
       Ovintiv's charter and bylaws that appear to substantively affect
shareholder rights that are
       not contained in or differ from Encana's governing documents, including:

           the inclusion of an exclusive forum provision designating the Court
of Chancery of
           the State of Delaware as the sole and exclusive forum for certain
types of actions and
           proceedings that may be initiated by stockholders;
           an increase in the percentage of stockholders required to call a
special meeting; and
           the elimination of stockholders' ability to take action by written
consent.
 Corey D. Code
1847432 Alberta ULC
November 26, 2019
Page 2

      Please refer to Rule 14a-4(a)(3) of Regulation 14A and Question 101.02 of
the
      Compliance and Disclosure Interpretations (Regarding Unbundling under
Rule 14a-
      4(a)(3) Generally), available on our website. In addition, expand your
Comparison of
      Rights of Encana Shareholders and Ovintiv Stockholders to discuss the
exclusive forum
      provision included in the Ovintiv Certificate of Incorporation.
2.    We note that you have filed "short-form" tax opinions as Exhibits 8.1 and
8.2. Please
      revise to clearly state that the disclosure in the Canadian and U.S.
Federal Income Tax
      Considerations sections beginning on pages 76 and 85, respectively, is
the opinion of the
      respective counsels, identify each material tax consequence being opined
upon and
      identify the tax counsels rendering each opinion. For guidance, refer to
Section III.B.2 of
      Staff Legal Bulletin No. 19.
        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844
or, in her
absence, Karina Dorin, Attorney-Adviser, at (202) 551-3763 with any questions.



                                                            Sincerely,
FirstName LastNameCorey D. Code
                                                            Division of
Corporation Finance
Comapany Name1847432 Alberta ULC
                                                            Office of Energy &
Transportation
November 26, 2019 Page 2
cc:       Andrew J. Foley
FirstName LastName