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United States securities and exchange commission logo





                             December 1, 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 10-Q for the
quarter ended June 30, 2022
                                                            Response letter
dated September 28, 2022
                                                            File No. 1-09447

       Dear Neal West:

              We have reviewed your September 28, 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
       September 28, 2022 letter.

       Response Letter Dated September 28, 2022

       Form 10-Q for the Quarter Ended June 30, 2022
       Item 2. Management's Discussion and Analysis of Financial Condition and
Results of Operations
       Selected Operational and Financial Information, page 25

   1.                                                   We note your response
to our prior comment 2. We continue to believe that the
                                                        adjustment in your
Adjusted EBITDA measure for "Adjustments to plant-level LIFO"
                                                        represents a tailored
accounting measure and is inconsistent with the guidance in Question
                                                        100.04 of the
Compliance & Disclosure Interpretations on Non-GAAP Financial
                                                        Measures. Please remove
this adjustment in future filings.
       Selected Operational and Financial Information, page 33
 Neal West
Kaiser Aluminum Corp.
December 1, 2022
Page 2

2.       We note your response to our prior comment 1. Please expand your
disclosure to provide
         more detail of the nature of the costs included in the "Hedged Cost of
Alloyed Metal
         amounts." For example, please provide a separate line for the metal
cost related to all
         contracts that are priced at the Midwest Transaction Price separately
from the costs related
         to contracts which have a hedged cost component, so that the straight
pass-through of
         costs is distinguished from the hedged amounts. In addition, your VAR
measure should
         be re-titled to more clearly indicate that the amount represents a
subcomponent or
         breakout of your consolidated revenue amount. Please revise
accordingly.
      You may contact Charles Eastman at (202) 551-3794 or Claire Erlanger at
(202) 551-
3301 with any questions.



FirstName LastNameNeal West                                    Sincerely,
Comapany NameKaiser Aluminum Corp.
                                                               Division of
Corporation Finance
December 1, 2022 Page 2                                        Office of
Manufacturing
FirstName LastName
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