<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
                                                            March 7, 2025

Christopher Forsythe
Chief Financial Officer
Atmos Energy Corp
1800 Three Lincoln Centre
5430 LBJ Freeway
Dallas, TX 75240

       Re: Atmos Energy Corp
           Form 10-K for the Fiscal Year ended September 30, 2024
           Filed November 18, 2024
           File No. 001-10042
Dear Christopher Forsythe:

       We have reviewed your filing and have the following comment.

       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
the 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.

Form 10-K for the Fiscal Year ended September 30, 2024
Properties, page 21

1.     We note your disclosure regarding the underground distribution and
transmission
       mains, indicating you have a program of "continuous inspection and
repair" and that
       you believe the system is in good condition. However, on page 78, you
reference an
       investigation by the National Transportation Safety Board of two
incidents early last
       year, though without providing details or context, or discussing the
implications.

       Based on the preliminary report, we understand that the investigation
pertains to two
       explosions that destroyed homes that were served by your natural gas
distribution
       system in Jackson, Mississippi, and that you had known of gas leaks in
close
       proximity to the explosions beforehand and subsequently found additional
leaks on
       mechanical couplings near the previously identified leaks, to include
the detection of
       subsurface gas near both locations where the explosions occurred and
near the
 March 7, 2025
Page 2

       foundations of adjacent homes. The report indicates the natural gas
distribution
       system serving those properties was installed in the 1960s and early
1970s.

       Given these findings, and considering your risk factor disclosure on
page 18,
       indicating significant capital expenditures are required to modernize
your distribution
       and transmission system, it appears that you should provide more details
regarding the
       condition, suitability, and adequacy of your pipeline systems, such as
the age of those
       systems, incidence of leak detections, and programs to replace or
upgrade those
       systems to comply with Instruction 1 to Item 102 of Regulation S-K.

       For example, considering the age of the system associated with the
incidents, disclose
       your view on the remaining serviceability of the 50-60 year-old pipeline
system, and
       clarify how the age of your other pipleline systems compare, with
quantitative details
       that provide meaningful differentiation based on the age of your
systems.

       Please discuss the nature and scope of any plans to replace or upgrade
the aging
       systems in your network, to include the timeframe, duration, and
estimated costs, or
       clarify if your approach is limited to conducting repairs, in which case
also discuss the
       limitations of that approach. Please also discuss any factors that
hinder your ability to
       upgrade and replace systems that are near the end of their servicable
lives.


        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 Mark Wojciechowski at 202-551-3759 or Karl Hiller at
202-551-3686
if you have questions regarding comments on the financial statements and
related matters.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of Energy &
Transportation
</TEXT>
</DOCUMENT>
