United States securities and exchange commission logo

                             September 21, 2022

       Bethany M. Owen
       Chair, President and Chief Executive Officer
       ALLETE, Inc.
       30 West Superior Street
       Duluth, MN 55802

                                                        Re: ALLETE, Inc.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2021
                                                            Filed February 16,
                                                            File No. 001-03548

       Dear Ms. Owen:

              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

              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 Fiscal Year Ended December 31, 2021


   1.                                                   We note that you
provided more expansive disclosure in your 2021 Corporate
                                                        Sustainability Report
than you provided in your SEC filings. Please advise us what
                                                        consideration you gave
to providing the same type of climate-related disclosure in your
                                                        SEC filings as you
provided in these reports.
       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page

   2.                                                   We note your disclosure
on page 100 stating that you are taking certain steps to address
                                                        climate change. Revise
your disclosure to identify any past and/or future capital
                                                        expenditures for
climate-related projects. As part of your response, provide quantitative
                                                        information for these
types of expenditures for each of the periods for which financial
                                                        statements are
presented in your Form 10-K and for any future periods.
 Bethany M. Owen
September 21, 2022
Page 2
3.       You provide disclosure on page 32 of your Form 10-K regarding your
exposure to
         reputational risk. Please expand this disclosure to address the
consequences of
         reputational risks resulting from operations that produce greenhouse
gas emissions,
         including, but not limited to, impacts to your credit ratings or your
ability to access
4.       We note your disclosure on pages 32-33 regarding the physical risks of
climate change. If
         material, further discuss the physical effects of climate change on
your operations and
         results. This disclosure may include quantification of weather-related
damages to your
         property or operations and weather-related impacts on the cost or
availability of
         insurance. Include quantitative information with your response for
each of the periods
         covered by your Form 10-K and, as applicable, tell us about
expectations for future
5.       You state that your businesses are in substantial compliance with
currently applicable
         environmental regulations. Please tell us about and quantify
compliance costs related to
         climate change your businesses have incurred during the last three
6.       We note the reference to the sale of renewable energy credits on page
81 of your Form 10-
         K. Please tell us about the purchase or sale of carbon credits or
offsets and the effects on
         your business, financial condition, and results of operations. Provide
         information with your response for each of the periods for which
financial statements are
         presented in your Form 10-K and amounts budgeted for future periods.
        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 Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Horowitz, Accounting Branch Chief, at (202) 551-3311 with any questions.

FirstName LastNameBethany M. Owen                               Sincerely,
Comapany NameALLETE, Inc.
                                                                Division of
Corporation Finance
September 21, 2022 Page 2                                       Office of
Energy & Transportation
FirstName LastName