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                             January 12, 2022

       Jeffry M. Householder
       President & Chief Executive Officer
       Chesapeake Utilities Corporation
       909 Silver Lake Boulevard
       Dover, DE 19904

                                                        Re: Chesapeake
Utilities Corporation
                                                            Form 10-K for the
Fiscal Year ended December 31, 2020
                                                            Filed February 24,
2021
                                                            Response dated
December 28, 2021
                                                            File No. 001-11590

       Dear Mr. Householder:

              We have reviewed your December 28, 2021 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
       December 15, 2021 letter.

       Form 10-K for the Fiscal Year ended December 31, 2020

       Management's Discussion and Analysis, page 25

   1.                                                   We note that in
response to prior comment one, you propose to relabel your non-GAAP
                                                        measure from Gross
Margin to Contribution Margin, and to provide a reconciliation from
                                                        Operating Income to
Contribution Margin, though extended to also show your incomplete
                                                        cost of sales measure
as a reconciling item between Contribution Margin and Revenues.

                                                        You indicate that you
will provide parenthetical notations on the incomplete cost of sales
                                                        measures in future
filings, to identify depreciation and amortization as the excluded
                                                        amount. However, the
reconciliation proposed includes a parenthetical notation along
                                                        with the incomplete
cost of sales measure, referencing the    items shown above,    which
 Jeffry M. Householder
Chesapeake Utilities Corporation
January 12, 2022
Page 2
         seems to imply that all operations and maintenance expenses, a gain
from settlement, and
         other taxes are similarly attributable to cost of sales, and that your
measure of operating
         income is thereby the same as gross margin in accordance with GAAP. We
previously
         observed that some costs within operations and maintenance expenses
appeared to be
         attributable to cost of sales based on your description on page 60.
Please clarify the extent
         to which all of the costs referenced above, from your proposed
disclosure, are in your
         view appropriately attributable to costs of sales, in accordance with
GAAP.

         Given the nature of your non-GAAP measure, we continue to believe that
you will need to
         present Gross Margin in accordance with GAAP as the most comparable
measure for use
         in the reconciliation, which should be distinct and apart from any
incremental
         comparisons or reconciliations to operating income or to revenues. If
you choose to
         present such incremental disclosures utilizing the non-GAAP measure,
these should be
         accompanied by corresponding disclosures utilizing Gross Margin in
accordance with
         GAAP, having equal or greater prominence. We reissue prior comment
one.
       You may contact Joseph Klinko at (202) 551-3824 or Lily Dang at (202)
551-3867
with any questions.



FirstName LastNameJeffry M. Householder                        Sincerely,
Comapany NameChesapeake Utilities Corporation
                                                               Division of
Corporation Finance
January 12, 2022 Page 2                                        Office of Energy
& Transportation
FirstName LastName