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United States securities and exchange commission logo





                              August 26, 2020

       Lars Christian Bacher
       Executive Vice President and Chief Financial Officer
       Equinor ASA
       Forusbeen 50, N-4035
       Stavanger, Norway

                                                        Re: Equinor ASA
                                                            Form 20-F for the
Fiscal Year Ended December 31, 2019
                                                            Filed March 20,
2020
                                                            File No. 001-15200

       Dear Mr. Bacher:

              We have reviewed your filing 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 20-F for the Fiscal Year Ended December 31, 2019

       Operational Performance
       Development of Reserves, page 66

   1.                                                   Expand the discussion
of the changes in the net quantities of your proved undeveloped
                                                        reserves to include an
appropriate narrative explanation relating to each of the line items
                                                        you identity on page
67, e.g. revisions and improved recovery, extensions and discoveries,
                                                        sales and purchases. To
the extent that two or more unrelated factors are combined to
                                                        arrive at the overall
change for a line item, your disclosure should separately identify and
                                                        quantify each
individual factor that contributed to a material change so that the change in
                                                        net reserve quantities
between periods is fully explained.

                                                        The disclosure of
revisions in the previous estimates of your proved undeveloped reserves
                                                        in particular should
identify the individual factors such as the changes caused by
                                                        commodity prices, well
performance, unsuccessful and/or uneconomic proved
 Lars Christian Bacher
FirstName  LastNameLars Christian Bacher
Equinor ASA
Comapany
August 26, NameEquinor
            2020       ASA
August
Page 2 26, 2020 Page 2
FirstName LastName
         undeveloped locations or the removal of proved undeveloped locations
due to changes in a
         previously adopted development plan. Refer to Item 1203(b) of
Regulation S-K.

         This comment also applies to the significant changes that occurred in
the net quantities of
         total reserves provided on page 245 for each line item shown in the
reconciliation, other
         than production, and for each of the periods presented, e.g. the
periods ending December
         31, 2019, 2018 and 2017, respectively. Refer to FASB ASC 932-235-50-5
and Item
         302(b) of Regulation S-K, respectively.
2.       The disclosure provided on page 68 indicates    some    development
activities will take
         place more than five years from the disclosure date. In this regard,
you appear to identify
         a single project, the Martin Linge field in Norway, where development
has been going on
         for more than five years.

         Revise your disclosure to clarify if the total amount of proved
undeveloped reserves that
         will not be developed within five years of initial disclosure is
material and if such reserves
         are limited to a single field and country, e.g. the Martin Ling field
in Norway.

         To the extent that such reserves are material, but not limited to the
Martin Linge field,
         expand your disclosure to explain the reasons why material amounts of
proved
         undeveloped reserves in individual fields or countries remain
undeveloped for five years
         or more after disclosure as proved reserves. Refer to Item 1203(d) of
Regulation S-K and
         the answer to question 131.03 in the Compliance and Disclosure
Interpretations (C&DIs),
         respectively.
Supplementary Oil and Gas Information (Unaudited)
Oil and Gas Reserve Quantities, page 240

3.       The change in the total net quantities of proved reserves attributed
to extensions and
         discoveries appears to be significantly greater than the corresponding
change in the net
         quantities of proved undeveloped reserves for two of the last three
fiscal years presented,
         e.g. differences between the comparable figures of approximately 26%
and 22% for the
         periods ending December 31, 2019 and 2017, respectively. Expand the
discussion of the
         changes in your total proved reserves attributed to extensions and
discoveries to explain
         the reason(s) for these differences. Refer to FASB ASC 932-235-50-5.
        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.
 Lars Christian Bacher
Equinor ASA
August 26, 2020
Page 3

       You may contact John Hodgin, Petroleum Engineer, at (202) 551-3699 if
you have
questions regarding the engineering comments. Please contact Brad Skinner,
Office Chief, at
(202) 551-3489 with any other questions.



FirstName LastNameLars Christian Bacher                   Sincerely,
Comapany NameEquinor ASA
                                                          Division of
Corporation Finance
August 26, 2020 Page 3                                    Office of Energy &
Transportation
FirstName LastName
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