Kaiser Aluminum Corporation
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JOHN M. DONNAN
Vice President, Secretary and General Counsel |
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VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
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Re:
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Kaiser Aluminum Corporation |
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Registration Statement on Form S-1 |
Ladies and Gentlemen:
Transmitted herewith for filing with the Securities and Exchange Commission (
“SEC”) is a
Registration Statement on Form S-1 (the
“Registration Statement”) relating to the registration of
2,895,648 shares of common stock of Kaiser Aluminum Corporation (the
“Company”) pursuant to the
Securities Act of 1933, as amended (the
“Securities Act”). The applicable filing fee, in the
amount of $11,929, was transmitted by wire transfer for
the Company’s account (CIK
000081596) to
the SEC lockbox account at Mellon Bank in Pittsburgh, Pennsylvania.
The Company would appreciate very much being informed as soon as possible as to the nature of
the review, if any, to which the Registration Statement may be subject. In this regard, we
respectfully direct the Staff’s attention to the fact that
the Company is currently working with
the SEC’s Office of the Chief Accountant (
“OCA”) to pre-clear its proposed accounting treatment at
and after
the Company’s recent emergence from chapter 11 bankruptcy of its contingent payment
obligations to two voluntary employees’ beneficiary associations (
“VEBAs”). In addition, the
Company expects to review with the OCA its accounting treatment of the 2004 accounting surrounding
the termination of its pre-petition postretirement medical plan and the creation of the VEBAs. The
Company anticipates that the process with the OCA will run concurrently with any review of the
Registration Statement by the Staff and will be completed prior to the Registration Statement being
declared effective.
Please
note that
the Company requests that the SEC permit
the Company’s request for the
acceleration of the effective date of the Registration Statement be made orally or by facsimile in
accordance with Rule 461(a) of Regulation C (the
“Rule”). Pursuant to the Rule, please also be
advised that
the Company and its underwriters are aware of their obligations under the Securities
Act and are prepared to provide, at the time of the acceleration request, the prospectus
dissemination information that is typically set forth in a written acceleration request.
