 | 27422 Portola Parkway, Suite 200 Foothill Ranch, CA 92610-2830 January 25, 2012 |
Mr. Terence O'Brien
Accounting Branch Chief
Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Kaiser Aluminum Corporation |
Form 10-K for the Fiscal Year Ended December 31, 2010
filed February 22, 2011
File No. 52105
Dear Mr. O'Brien:
Dear Mr. O'Brien:
On behalf of Kaiser Aluminum Corporation (the “Company”), I am writing to respond to your letter dated January 20, 2012, containing comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in regard to the above-referenced filing.
For ease of reference, I have included the text of the Staff's comments in bold-face type below, followed in each case by the Company's response.
Form 10-K for the Fiscal Year Ended December 31, 2010
Note 4 - Conditional Asset Retirement Obligations, page 79
1. | We have read your response to prior comment 2 from our letter dated December 29, 2011. In future filings please provide a reconciliation of the beginning and ending aggregate carrying amount of asset retirement obligations showing separately the changes attributable to the following components, whenever there is a significant change in any of these components during the reporting period: |
• | Liabilities incurred in the current period |
• | Liabilities settled in the current period |
• | Accretion expense |
• | Revisions in estimated cash flows |
Review ASC 410-20-50-1 for guidance.
Response: The Company notes the Staff's comment and will provide a reconciliation of the beginning and ending aggregate carrying amount of asset retirement obligations showing separately the changes attributable to the above-referenced components in future filings whenever there is a significant change in any of these components during the reporting period.
Mr. Terence O'Brien
Securities and Exchange Commission
January 25, 2012
Page 2
If you have any additional questions regarding the foregoing, please do not hesitate to contact me at (949) 614-1770 or by email at dan.rinkenberger@kaiseraluminum.com.
| Very truly yours, | |
| /s/ Daniel J. Rinkenberger | |
| Daniel J. Rinkenberger | |
| cc: | John M. Donnan, Kaiser Aluminum Corporation |
Cherrie Tsai, Kaiser Aluminum Corporation | |
Troy B. Lewis, Jones Day | |