July 23, 2024

Rebecca A. Hoyt
Senior Vice President and Chief Accounting Officer
APA Corp
One Post Oak Central
2000 Post Oak Boulevard, Suite 100
Houston, Texas 77056-4400

       Re: APA Corp
           Annual Report on Form 10-K for the fiscal year ended December 31, 
2023
           Filed February 22, 2024
           File No. 001-40144
Dear Rebecca A. Hoyt:

       We have reviewed your filing and have the following comment(s).

       Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your 
response.

       After reviewing your response to this letter, we may have additional 
comments.

Annual Report on Form 10-K for the fiscal year ended December 31, 2023
Operating Areas
Other Exploration, page 6

1.
       You disclose that successful appraisal of two key oil discoveries 
"confirmed combined
       recoverable resources of an estimated 700 million barrels of oil for the 
two fields". Please
       note that disclosure of quantities other than reserves in an annual 
report on Form 10-K is
       generally prohibited. See the instruction to Item 1202 of Regulation S-K 
and revise your
       disclosure accordingly.
Business Overview
Upstream Exploration and Production
Drilling Statistics, page 7

2.     We note that 7.7 nets wells (10%) of the 73.8 net development wells 
drilled in Egypt
       during 2023 were dry; however, during the prior five years (2018 to 
2022) only 3 net
 July 23, 2024
Page 2

       development wells (1%) of the total 226.7 net development wells drilled 
in Egypt were
       dry. Please provide as supplemental information a reasonably detailed 
explanation for the
       higher dry hole rate during 2023, including any effect on your future 
development plans
       in Egypt. Additionally, tell us the following:
           Whether any proved undeveloped reserves were included for the 7.7 
net dry wells at
           year-end 2022, and if so, the quantity of those reserves and where 
the downward
           revision is reflected in the 2023 reserve roll-forward;
           Whether and how actual drilling results differed from assumptions 
underlying the
           decision to drill these wells;
           Whether the results on these wells led you to reevaluate reserve 
estimates for any
           other wells; and,
           Where any downward revisions attributable to any related wells are 
reflected in the
           2023 reserve roll-forward.


        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.

        Please contact Sandra Wall at 202-551-4727, Petroleum Engineer, or Brad 
Skinner,
Office Chief, at 202-551-3489 if you have questions regarding the engineering 
comments or
related matters.



                                                          Sincerely,

                                                          Division of 
Corporation Finance
                                                          Office of Energy & 
Transportation