United States securities and exchange commission logo September 2, 2020 Sean O'Brien Group Vice President and Chief Financial Officer DCP Midstream, LP 370 17th Street , Suite 2500 Denver , Colorado 80202 Re: DCP Midstream, LP Form 10-K for the Fiscal Year Ended December 31, 2019 Filed on February 21, 2020 File No. 001-32678 Dear Mr. O'Brien: We have limited our review of your filing to the financial statements and related disclosures 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 10-K for the Fiscal Year Ended December 31, 2019 Item 7. Management s Discussion and Analysis of Financial Condition and Results of Operations Reconciliation of Non-GAAP Measures, page 71 1. We note your presentation of the non-GAAP measure gross margin. Please present a reconciliation for this non-GAAP measures in accordance with Item 10(e)(1)(i)(B) of Regulation S-K. In doing so, reconcile this measure to the most directly comparable GAAP measures, i.e. gross margin that includes depreciation, depletion and amortization. If you do not believe gross margin that includes depreciation, depletion and amortization expense is the most directly comparable GAAP measure, please tell us why in your response. Item 7A. Quantitative and Qualitative Disclosures about Market Risk, page 79 2. Please revise your disclosure to provide the quantitative and qualitative disclosures Sean O'Brien DCP Midstream, LP September 2, 2020 Page 2 required under Item 7A of Form 10-K and Item 305 of Regulation S-K for your natural gas trading and marketing and NGL proprietary trading. Your revised disclosure should address, but not be limited to, the policies and procedures, internal controls and risk limits used to manage your trading activities. In closing, 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. You may contact Robert Babula, Staff Accountant at (202) 551-3339, or Gus Rodriguez, Branch Chief at (202) 551-3752 with any questions. FirstName LastNameSean O'Brien Sincerely, Comapany NameDCP Midstream, LP Division of Corporation Finance September 2, 2020 Page 2 Office of Energy & Transportation FirstName LastName