OXYOccidental Petroleum

We note from your disclosure on page 3 that the midstream and marketing segment includes your low-carbon ventures businesses (“OLCV”) and that these businesses seek not only to leverage carbon management in your operations but also to “strategically partner with other industries to help reduce their emissions.” We further note disclosure on page 44 that OLCV provides services to third parties to facilitate the

Rest of the question

implementation of their CCUS projects and that “OLCV is fostering emerging technologies, including DAC and low-carbon power sources, and other business models with the potential to position Occidental as a leader in the production of low-carbon energy and products.” Please explain in sufficient detail how you evaluated whether OLCV is considered a separate operating segment under the guidance of FASB ASC 280-10-50. As part of your response, please address the following: • If you do not consider OLCV to be a separate operating segment, provide an analysis to support your position in accordance with FASB ASC paragraphs 280-10-50-1 through 50-9. • If you do consider OLCV to be a separate operating segment that you aggregate for reporting purposes into the midstream and marketing segment, provide an analysis to support your position that OLCV meets the aggregation criteria in FASB ASC paragraph 280-10-50-11.

We respectfully advise the Staff that the Company regularly reviews its segment analysis and will continue to assess OLCV given the expected continued investment in this portfolio of assets. The Company’s December 2023 analysis, particularly with respect to OLCV, concluded that OLCV did not meet the operating segment criteria under FASB ASC paragraphs 28-10-50-1 through 50-9.

Rest of the answer

The below discussion summarizes the Company’s analysis of the applicable sections of ASC 280-10-50-1 through 50-9.

The Company’s President and CEO is the Chief Operating Decision Maker (CODM) and is responsible for allocating resources and assessing the performance across the Company’s operations. The oil and gas, midstream and marketing, and chemicals segments each have separate segment management directly accountable to the CODM as described by ASC 280-10-50-7, whereas OLCV does not have a segment manager who is directly accountable to the CODM. The segment managers allocate resources within their segments and are not part of the CODM function.

The CODM reviews a consolidated financial package for the Company and discrete financial packages for each of the Company’s three operating segments: oil and gas, midstream and marketing and chemicals. All reports present the Company’s business activities classified in these three areas, with the corporate and eliminations included in the consolidated package.

OLCV seeks to partner with other industries by offering CO2 sequestration services at one of several still to be developed sequestration hubs. OLCV also seeks to capture CO2 directly from the atmosphere through its first direct air capture plant, which is expected to be completed in mid-2025. OLCV’s operating results are incorporated in the midstream and marketing segment’s financial package as this segment also includes the Company’s legacy CO2 processing and transportation activities. Legacy midstream CO2 assets may be utilized for low-carbon projects, at such time that any sequestration hubs or direct air capture facilities are completed. OLCV has no material intercompany or third-party revenue as the direct air capture and sequestration projects are currently in pre-operational, developmental stage. OLCV’s remaining activity is related to several equity method investments the aggregate book value of which is less than 1% of the

Company’s total assets. OLCV’s net assets and pre-tax profit operating losses are less than 5% and 0.6%, respectively, of the Company’s corresponding consolidated amounts for 2023.

Because OLCV’s business activities are still in development, information about OLCV revenue and expenses are not presented or regularly reviewed as discrete financial information by the CODM, therefore OLCV does not meet the second characteristic of ASC 280-10-50-1 and is not a separate operating segment. ASC 280-10-50-3 indicates that start-up activities may be considered an operating segment, however, at this time, the OLCV operating results do not rise to the significance for the CODM to review separately.

The aggregation criteria in FASB ASC paragraph 280-10-50-11 are not applicable as OLCV is not a separate operating segment.

Read in the reply ↗

Tell us the quantity of reported reserves that are attributable to investments that are accounted for by the equity method and where they are reflected in your supplemental oil and gas reserve disclosure. Additionally, explain to us how your presentation takes into consideration the guidance in FASB ASC paragraph 932-235-50-8(c).

We respectfully advise the Staff that the Company does not have any oil and gas reserves or production associated with investments that are accounted for under the equity method for any of the periods presented in the Form 10-K. The equity method investee referenced in footnote (b) to the Company’s presentation of results of operations on page 121 is related to the Company’s investment in a Gulf of Mexico well containment company that has no oil and gas reserves or production. Read in the reply ↗

Footnote (b) to your presentation of results of operations indicates, in part, that revenues include income from equity investments. Explain to us how this presentation takes into consideration the guidance of FASB ASC paragraph 932-235-50-28.

We respectfully advise the Staff that the income associated with the equity method investments referenced in footnote (b) accounts for 0.1% or less of total revenues for each period presented in the Form 10-K. Due to its immaterial nature, the

Company will remove the reference to the equity method investees from similar disclosure in future filings.

If you need any further information or elaboration, or if you wish to discuss any of the information presented above, please call me at your convenience at (713) 985-6901. Read in the reply ↗

You disclose that you have over 8,500 drilling location in your horizontal inventory. Expand this disclosure to clarify the nature of these locations, including whether they are individual, specifically identified drilling locations and the extent to which they represent proved or unproved locations.

The Company acknowledges the Staff’s comment. In any future filings in which the Company discloses the number of its drilling locations, the Company will expand this disclosure to clarify the nature of these locations, including whether they are individual, specifically identified drilling locations and the extent to which they represent proved or unproved locations.

Rest of the answer

The Company proposes to revise any such disclosure in a manner similar to the following in reports going forward:

“The Company has over [ ] individual, specifically identified drilling locations in its horizontal inventory located in the Midland and Delaware sub-basins of the Permian Basin. This inventory was developed using data gathered from our appraisal efforts and development drilling, along with offset operators drilling activities. As of year end, [ ] of these represented proved locations.”

Read in the reply ↗

The discussion of quarterly results appearing on pages two and three of the earnings release provided under Exhibit 99.1 is based on non-GAAP “core earnings”, and does not include a corresponding presentation and discussion of GAAP results. This is inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016, in particular C&DI 102.10.

Rest of the question

Please review this guidance when preparing your next earnings release.

The Company acknowledges the Staff’s comment on the updated Compliance and Disclosure Interpretations issued subsequent to the filing of the Form 8-K. In future documents filed or furnished with the Commission, the Company will include a corresponding presentation and discussion of GAAP results along with the presentation of non-GAAP “core earnings”, as applicable. The Company will apply the guidance consistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016, in particular C&DI 102.10. Read in the reply ↗

We note that cash used for capital expenditures plus dividends exceeded cash flow from operations for the year ended December 31, 2015 and for the quarter ended March 31, 2016, despite significant reductions in capital expenditures in response to the current commodity price environment.

Rest of the question

We also note that restricted cash, which had been used to fund dividends in recent periods, had been fully utilized as of March 31, 2016. Expand your discussion under this section to describe the impact of these trends on your cash management decisions, including with respect to the payment of dividends. See Section IV of SEC Release 34-48960.

The Company acknowledges the Staff’s comment and will provide additional disclosures in future annual and quarterly reports, as applicable, describing the impact of capital expenditure and cash flow trends on the Company’s cash management decisions, including with respect to dividends. The Company expects that such additional disclosure will vary from quarter-to-quarter in response to fluctuations in the commodity price environment, demand for the Company’s products, and other market conditions and contingencies.

Rest of the answer

In the future, the Company proposes to revise its disclosure in a manner similar to the following, to be modified as appropriate to actual results and market conditions:

“At [ ], 2016, Occidental had $[ ] billion in cash. Income and cash flows are largely dependent on the oil and gas segment’s realized prices, sales volumes and operating costs. In the [ ] quarter, Occidental continued to significantly reduce its capital expenditures compared to the prior year period. Subsequent to the quarter end, the oil and natural gas commodity price environment continued to improve, and, with a continued reduction in capital expenditures and forecasted operational improvements, Occidental expects to fund its liquidity needs, including future dividend payments, through cash on hand, cash generated from operations, monetization of non-core assets or investments and, if necessary, through future borrowings or proceeds from other forms of capital issuance.”

Occidental acknowledges that:

•

Occidental is responsible for the adequacy and accuracy of the disclosure in the filing;

Staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and

Occidental may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you need any further information or elaboration, or if you wish to discuss any of the information presented above, please call me at your convenience at 713-215-7123.

Read in the reply ↗