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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,
2022
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
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 Fiscal Year Ended December 31, 2021
General
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
36
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
ALLETE, Inc.
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
capital.
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
periods.
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
years.
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
quantitative
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
Ethan
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