TEXT-EXTRACT 2 filename2.txt March 10, 2020 Christine Vaughan Senior Vice President, Chief Financial Officer and Treasurer UNITIL CORP 6 Liberty Lane West Hampton, New Hampshire 03842-1720 Re: UNITIL CORP Form 10-K for the Year Ended December 31, 2019 10-K filed January 30, 2020 File No. 001-08858 Dear Ms. Vaughan : We have limited our review of your filing to the financial statements and related disclosures 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 Year Ended December 31, 2019 Management's Discussion and Analysis of Financial Condition and Results of Operations Results of Operations Gas Sales, Revenues and Margin Gas Operating Revenues and Sales Margin, page 30 1. We note your presentation of the non-GAAP measures Gas Sales Margin and Electric Sales Margin. Please present reconciliations for these non-GAAP measures in accordance with Item 10(e)(1)(i)(B) of Regulation S-K. In doing so, reconcile these measures to the most directly comparable GAAP measure of gross margin. If you do not believe gross margin that includes depreciation and amortization is the most directly comparable GAAP measure, please tell us why in your response. Christine Vaughan UNITIL CORP March 10, 2020 Page 2 Financial Statements Notes to Consolidated Financial Statements Note 1: Summary of Significant Accounting Policies Utility Revenue Recognition, page 53 2. We note your alternative revenue programs. Please confirm for us and disclose whether you meet all three of the criteria within 980-605-25-4 for recognition of alternative revenues in connection with your rate adjustment mechanisms. Additionally, please tell us and disclose the methodology used to calculate and present revenues from alternative revenue programs. In closing, 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 Yong Kim, Staff Accountant at (202) 551-3323 or Robert Babula, Senior Staff Accountant at (202) 551-3339 with any questions. FirstName LastNameChristine Vaughan Sincerely, Comapany NameUNITIL CORP Division of Corporation Finance March 10, 2020 Page 2 Office of Energy & Transportation FirstName LastName