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United States securities and exchange commission logo





                                July 21, 2022

       Neal West
       Executive Vice President and Chief Financial Officer
       Kaiser Aluminum Corp.
       27422 Portola Parkway, Suite 200
       Foothill Ranch , California 92610-2831

                                                        Re: Kaiser Aluminum
Corp
                                                            Form 10-K for the
year ended December 31, 2021
                                                            Form 8-K filed
April 20, 2022
                                                            File No. 1-09447

       Dear Mr. West:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 the year ended December 31, 2021

       Management's Discussion and Analysis of Financial Condition and Results
of Operations
       Results of Operations
       Fiscal 2021 Summary
       Cost of Products Sold, page 32

   1.                                                   We note you disclose
'higher hedged metal prices' as a driver of increased cost of products
                                                        sold. You further
disclose that the "increase in net manufacturing conversion and other
                                                        costs was primarily due
to the addition of Packaging and additional overhead associated
                                                        with the related
increase in volume, as well as higher labor, energy, freight, benefit and
                                                        metal cost driven by
supply chain inefficiencies, inflation and labor shortages." In future
                                                        filings, please expand
to identify the principal factors contributing to the inflationary
                                                        pressures the company
has experienced and clarify the resulting impact to the company.
                                                        In addition, please
also identify initiatives planned or taken, if any, to mitigate inflationary
                                                        pressures.
 Neal West
FirstName  LastNameNeal
Kaiser Aluminum  Corp. West
Comapany
July       NameKaiser Aluminum Corp.
     21, 2022
July 21,
Page  2 2022 Page 2
FirstName LastName
Select Operational and Financial Information, page 33

2.       We note your disclosure of Value Added Revenue or    VAR    which
appears to be
         calculated as Net Sales less Hedged Cost of Alloyed Metal. We also
note from your
         disclosure on page 30 that Hedged Cost of Alloyed Metal refers to the
cost of aluminum at
         the average Midwest Transaction Price plus the cost of alloying
elements and any realized
         gains and/or losses on settled hedges related to the metal sold in the
reference period.
         Please clarify the nature of the items included in the Hedged Cost of
Alloyed Metal. In
         doing so, specify if the entire amount represents true pass-through
costs to the customer
         and clarify, if true, that this amount has no impact on the dollar
amount of your gross
         profit. In this regard we note your disclosures on page 9 and
elsewhere in your filing that
         you    generally    are able to pass through costs of aluminum and
other alloyed metals.
         Please advise.
Notes to the Financial Statements
Note 9. Debt and Credit Facility, page 78

3.       Please revise to include disclosure of the combined aggregate amount
of maturities and
         sinking fund requirements for all long-term debt borrowings for each
of the five years
         following the date of the latest balance sheet presented. See guidance
in ASC 470-10-50-
         1.
Form 8-K filed April 20, 2022

Exhibit 99.1
First Quarter 2022, page 2

4.       It appears that management has given your non-GAAP measure, Adjusted
EBITDA
         greater prominence than the comparable GAAP measure as you are
discussing Adjusted
         EBITDA before reported net income in both the Management Summary
section and the
         First Quarter 2022 discussion of your earnings release. Please revise
future filings to give
         greater or equal prominence to the GAAP measures. Refer to Instruction
2 of Item 2.02 of
         Form 8-K, Item 10(e)(1)(i)(A) of Regulation S-K and Question 102.10 of
the Division of
         Corporation Finance C&DIs on Non-GAAP Financial Measures.
       In closing, 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.

      You may contact Charles Eastman at (202) 551-3794 or Claire Erlanger at
(202) 551-
3301 with any questions.



                                                               Sincerely,
 Neal West
Kaiser Aluminum Corp.
July 21, 2022
Page 3
FirstName LastNameNeal West
Comapany NameKaiser Aluminum Corp.
                                     Division of Corporation Finance
July 21, 2022 Page 3                 Office of Manufacturing
FirstName LastName
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