Exxon Mobil Corporation Patrick T. Mulva
5959 Las Colinas Boulevard Vice President and Controller
Irving, TX 75039-2298
972 444 1202 Telephone
972 444 1221 Facsimile
ExxonMobil
February 26, 2007
Ms. Jill S. Davis
Branch Chief
U. S. Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.W., Stop 7010
Washington, D.C. 20549
Re: Exxon Mobil Corporation
Form 10-K for the Fiscal Year ended December 31, 2005
Filed February 28, 2006
Form 10-Q for Fiscal Quarters ended March 31, 2006, June 30, 2006, and
September 30, 2006
Filed May 4, 2006 and August 4, 2006 and November 8, 2006
Response Letter Dated February 2, 2007
File No. 1-02256
Dear Ms. Davis:
On behalf of Exxon Mobil Corporation, please find enclosed our response to your
comment regarding the above filings set forth in your letter of February 9, 2007.
If you desire clarification of our responses, please direct any questions to Mr. David
Levy at 972-444-1290.
Very truly yours,
By: /s/ Patrick T. Mulva
----------------------------------------
Name: Patrick T. Mulva
Title: Vice President and Controller
Attachment
c: Ronald Winfrey
Mark Wojciechowski
ExxonMobils Response to the
Comments Included in the SEC Letter of February 9, 2007
Form 10-K for the Fiscal Year Ended December 31, 2005
Supplemental Information on Oil and Gas Exploration and Production Activities (unaudited), page 76
1. As requested in the Closing Comments section of our letter dated January 12, 2007, please provide us draft disclosures you anticipate including in your Form 10-K for the fiscal year ended December 31, 2006, to address previous comments one and three.
Attachment 1 provides the format that will be used in the supplemental information on oil and gas activities section in the Form 10-K to present the crude oil and natural gas liquids proved reserves year-end balances and the changes in the net quantities. The same format will be used for natural gas proved reserves. This format is consistent with illustration 4 in FAS 69.
We will expand our disclosure in the Management Discussion and Analysis, "Critical Accounting Policies - Oil and Gas Reserves" in the Form 10-K for the year ended December 31, 2006, as follows:
Beginning in 2004, the year-end reserves volumes as well as the reserves change categories shown in the proved reserves tables are calculated using December 31 prices and costs. These reserves quantities are also used in calculating unit-of-production depreciation rates and in calculating the standardized measure of discounted net cash flow. Regulations preclude the Corporation from showing in this document the reserves that are calculated in a manner that is consistent with the basis that the Corporation uses to make its investment decisions. The use of year-end prices for reserves estimation introduces short-term price volatility into the process since annual adjustments are required based on prices occurring on a single day. The Corporation believes that this approach is inconsistent with the long-term nature of the upstream business where production from individual projects often spans multiple decades. The use of prices from a single date is not relevant to the investment decisions made by the Corporation and annual variations in reserves based on such year-end prices are not of consequence to how the business is actually managed.
Revisions can include upward or downward changes in previously estimated volumes of proved reserves for existing fields due to the evaluation or re-evaluation of (1) already available geologic, reservoir or production data, (2) new geologic, reservoir or production data or (3) changes in year-end prices and costs that are used in the determination of reserves. This category can also include changes associated with the performance of improved recovery projects and significant changes in either development strategy or production equipment/facility capacity.
-2-
Exxon Mobil Corporation | ||||||||
Attachment 1 | ||||||||
Asia |
||||||||
Crude Oil and Natural Gas Liquids |
Pacific/ |
|||||||
United |
Middle |
Russia/ |
||||||
States |
Canada (1) |
Europe |
Africa |
East |
Caspian |
Other |
Total | |
Net proved developed and undeveloped reserves |
(millions of barrels) |
|||||||
of consolidated subsidiaries | ||||||||
January 1, 2004 |
2,792 |
1,194 |
1,184 |
2,742 |
615 |
850 |
512 |
9,889 |
Revisions |
54 |
(460) |
37 |
(243) |
(5) |
(120) |
(14) |
(751) |
Purchases |
- |
- |
- |
10 |
- |
- |
- |
10 |
Sales |
(113) |
(3) |
- |
- |
(16) |
- |
- |
(132) |
Improved recovery |
5 |
- |
- |
- |
- |
- |
- |
5 |
Extensions and discoveries |
16 |
4 |
3 |
144 |
2 |
- |
- |
169 |
Production |
(161) |
(108) |
(210) |
(209) |
(81) |
(6) |
(20) |
(795) |
December 31, 2004 |
2,593 |
627 |
1,014 |
2,444 |
515 |
724 |
478 |
8,395 |
Revisions |
(256) |
338 |
17 |
(8) |
78 |
(27) |
(2) |
140 |
Purchases |
- |
- |
- |
- |
- |
93 |
- |
93 |
Sales |
(96) |
(42) |
(1) |
- |
(11) |
(70) |
(7) |
(227) |
Improved recovery |
2 |
- |
3 |
- |
- |
- |
- |
5 |
Extensions and discoveries |
6 |
16 |
47 |
120 |
- |
- |
- |
189 |
Production |
(136) |
(107) |
(197) |
(244) |
(67) |
(13) |
(18) |
(782) |
December 31, 2005 |
2,113 |
832 |
883 |
2,312 |
515 |
707 |
451 |
7,813 |
Revisions |
- |
- |
- |
- |
- |
- |
- |
- |
Purchases |
- |
- |
- |
- |
- |
- |
- |
- |
Sales |
- |
- |
- |
- |
- |
- |
- |
- |
Improved recovery |
- |
- |
- |
- |
- |
- |
- |
- |
Extensions and discoveries |
- |
- |
- |
- |
- |
- |
- |
- |
Production |
- |
- |
- |
- |
- |
- |
- |
- |
December 31, 2006 |
- |
- |
- |
- |
- |
- |
- |
- |
Proportional interest in proved reserves | ||||||||
of equity companies | ||||||||
End of year 2004 |
402 |
- |
17 |
- |
1,169 |
911 |
- |
2,499 |
End of year 2005 |
413 |
- |
11 |
- |
1,381 |
873 |
- |
2,678 |
End of year 2006 |
- |
- |
- |
- |
- |
- |
- |
- |
Proved developed reserves, included above, as of | ||||||||
December 31, 2004 | ||||||||
Consolidated subsidiaries |
2,204 |
561 |
763 |
1,117 |
403 |
34 |
129 |
5,211 |
Equity companies |
347 |
- |
15 |
- |
642 |
600 |
- |
1,604 |
December 31, 2005 | ||||||||
Consolidated subsidiaries |
1,680 |
607 |
656 |
1,218 |
464 |
55 |
227 |
4,907 |
Equity companies |
326 |
- |
9 |
- |
725 |
574 |
- |
1,634 |
December 31, 2006 | ||||||||
Consolidated subsidiaries |
- |
- |
- |
- |
- |
- |
- |
- |
Equity companies |
- |
- |
- |
- |
- |
- |
- |
- |
(1) Includes total proved reserves attributable to Imperial Oil Limited of 347 million barrels in 2004, 634 million barrels in 2005 and xxx million barrels in 2006, as well as | ||||||||
proved developed reserves of 343 million barrels in 2004, 449 million barrels in 2005 and xxx million barrels in 2006, in which there is a 30.4 percent minority interest. |