United States securities and exchange commission logo
September 9, 2022
Avner Applbaum
Chief Financial Officer
Valmont Industries, Inc.
15000 Valmont Plaza
Omaha, Nebraska 68154
Re: Valmont Industries,
Inc.
Form 10-K for
Fiscal Year Ended December 25, 2021
Response Dated
August 26, 2022
File No. 001-31429
Dear Mr. Applbaum:
We have reviewed your August 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
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
July 29, 2022 letter.
Response Dated August 26, 2022
Risk Factors, page 10
1. Your response to prior
comment two states that technological changes related to climate
change manifest more as
opportunities than as risks, but it does not appear that your
response explains your
assessment of these risks. Please tell us about the risks related to
technological changes
you identified in your analysis and explain how you evaluated their
effect on your
business, financial condition, and results of operations. In addition, please
tell us about market
trends relevant to your business in the context of climate change,
including those that
could affect your competitive position in each of the markets that you
serve or that could
require a change in your business strategy.
Avner Applbaum
FirstName LastNameAvner Applbaum
Valmont Industries, Inc.
Comapany 9,
September NameValmont
2022 Industries, Inc.
September
Page 2 9, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
21
2. We note your response to prior comment four and reissue it in part.
Please tell us about
and quantify your capital expenditures for climate-related projects
budgeted for future
periods.
3. We note your response to prior comment five. Please further address
the following items:
Your response indicates that, beyond perceived increases in
product demand, you
have not identified any other material business trends as
indirect consequences of
climate-change regulations or business trends. Explain to us how
you evaluated the
business trends you considered for each of the items noted in our
prior comment
including causes of changes in demand for goods or services,
providing support for
your determinations of materiality.
Explain to us how you considered providing disclosure regarding
changes in demand
for alternative energy sources in connection with reducing energy
use and fossil fuels
across your operations.
Your response describes increased demand for certain products
as an indirect
consequence of climate-related regulation. Tell us how you
evaluated the materiality
of these opportunities for purposes of disclosure.
4. We note your response to prior comment six. Please further address the
following:
As it relates to arability of farmland and agricultural
production capacity in areas
affected by weather-related changes, please tell us how you
considered providing
disclosure that addresses risks associated with climate change
that may arise from
physical risks to entities other than yourself (for example, as
part of the risk factor
disclosure on pages 10-11 of your Form 10-K regarding cyclicality
in the industries
in which the ultimate consumers of your products operate).
Quantify for us the cost of insurance for each of the periods
covered by your Form
10-K.
Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at
202-551-3047 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of
Manufacturing