United States securities and exchange commission logo

                               November 4, 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
                                                            Response dated
October 26, 2022
                                                            File No. 001-03548

       Dear Bethany M. Owen:

              We have reviewed your October 26, 2022 response to our comment
letter 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
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       September 21, 2022 letter.

       Response dated October 26, 2022

       Management's Discussion and Analysis of Financial Condition and Results
of Operations, page

   1.                                                   Your response to prior
comment 2 does not appear to provide information regarding
                                                        future capital
expenditures for climate-related projects. Please tell us about and quantify
                                                        climate-related capital
expenditures made during 2022 and amounts budgeted for future
 Bethany M. Owen
FirstName LastNameBethany M. Owen
Comapany 4,
November  NameALLETE,
             2022        Inc.
Page 2    4, 2022 Page 2
FirstName LastName
2.       In response to prior comment 4, you state that you "have experienced
increasing rates and
         deductibles for property insurance, and lower sub-limits for natural
perils such as flooding
         and severe storms, with a larger impact at wind energy facilities
located in areas more
         susceptible to these weather events." Tell us how you considered
providing disclosure
         regarding these changes and future period weather-related impacts to
the cost or
         availability of insurance.
      Please contact Anuja A. Majmudar, Attorney-Adviser, at (202) 551-3844 or
Horowitz, Accounting Branch Chief, at (202) 551-3311 with any questions.


                                                               Division of
Corporation Finance
                                                               Office of Energy
& Transportation