SEC Company Response from ALGOMA STEEL INC (CIK 0000943945) — Sep 15, 2005
ALGOMA STEEL INC (CIK 0000943945)
Date: Sept. 15, 2005 · CIK: 0000943945 · Accession: 0001279569-05-000808
AI Filing Summary & Sentiment
Letter
Mr. John Hartz Senior Assistant Chief Accountant U.S. Securities and Exchange Commission Washington, DC 20549-7010
Dear Mr. Hartz:
Re: Form 40-F for the Fiscal Year Ended December 31, 2004
Form 6-K for the Fiscal Quarter Ended March 31, 2005
File No. 0-25870
In response to your letter of August 2, 2005, we have included the required consent from the independent accountant and the certification by the Chief Executive Officer and the Chief Financial Officer. We will be filing an amendment to include this consent. It is our intent to include the following narrative with the filing:
“The Company is filing an amendment to the 40-F filing for the fiscal year ended December 31, 2004. The amendment is for the provision of the consent of the independent accountant (Ernst & Young LLP) for inclusion of their audit report for the year ended December 31, 2004. There were no changes to any of the originally filed documents.”
You requested that we revise our table of contractual obligations to include interest payments on our debt and funding obligations for pension and post-employment benefit obligations. The estimated interest payments on the debt and the planned funding for pension and post-retirement benefit funding are summarized below. It is our intent, based on discussion with Gus Rodriguez, to ensure that this data is included in future filings.
Total
&
&
After
Years
Interest on Long-Term Debt
69.0
16.6
33.2
33.2
- (1
)
Pension Funding
136.4
45.0
91.4
-
- (2
)
Post-Employment Benefit Funding
46.1
14.2
31.9
-
- (3
)
(1)
The long-term debt matures in 2009. Interest payments are converted into Canadian dollars based on $1 Cdn = $.83 U.S.
(2)
The accuracy of this forecast of future cash flows depends on various factors such as actual return on plan assets, discount rates used to calculate obligations, rate of compensation increases and mortality rates. It is impossible to make a prediction of cash requirements beyond the term of the USWA labour contracts which expire in 2007.
(3)
The accuracy of this forecast of future cash flows depends on various factors such as discount rates used to calculate obligations, mortality rates and health escalation rates. It is impossible to make a prediction of cash requirements beyond the term of the USWA labour contracts which expire in 2007.
I have also attached a statement from the Company acknowledging several conditions as requested.
I trust that this addresses the items raised in your letter.
Yours truly,
ALGOMA STEEL INC.
/s/ GLEN MANCHESTER
Glen Manchester
Vice President - Finance and
Chief Financial Officer
GPM:all
Attachs.
STATEMENT BY ALGOMA STEEL INC.
Algoma Steel Inc. hereby certifies the following:
•
The Company is responsible for the adequacy and accuracy of the disclosure in their filings;
•
The Company acknowledges that staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and
•
The Company acknowledges that it cannot use SEC staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
/s/ DENIS TURCOTTE_______________________
Denis Turcotte
President and Chief Executive Officer
/s/ GLEN MANCHESTER_____________________
Glen Manchester
Vice President - Finance and Chief Financial Officer
Show Raw Text
CORRESP
1
filename1.htm
Correspondence with the SEC
Glen P. Manchester
Vice President - Finance And Chief Financial
Officer
Phone: 705-945-2470 Fax:
705-945-2203
Email:
gmanches@algoma.com
ALGOMA
STEEL
INC.
105 West Street
Sault Ste. Marie, Ontario, Canada P6A 7B4
Phone: 705-945-2351 Fax:
705-945-2203
August
31, 2005
VIA
COURIER
Mr.
John Hartz
Senior
Assistant Chief Accountant
U.S.
Securities and Exchange Commission
Washington,
DC 20549-7010
Dear
Mr. Hartz:
Re: Form
40-F for the Fiscal Year Ended December 31, 2004
Form
6-K for the Fiscal Quarter Ended March 31, 2005
File
No. 0-25870
In
response to your letter of August 2, 2005,
we have included the required consent from the independent accountant
and
the certification by the Chief Executive Officer and the Chief Financial
Officer. We will be filing an amendment to include this consent.
It is our
intent to include the following narrative with the
filing:
“The
Company is filing an amendment to the 40-F filing for the fiscal
year
ended December 31, 2004. The amendment is for the provision of the
consent
of the independent accountant (Ernst & Young LLP) for inclusion of
their audit report for the year ended December 31, 2004. There were
no
changes to any of the originally filed
documents.”
You
requested that we revise our table of
contractual obligations to include interest payments on our debt
and
funding obligations for pension and post-employment benefit obligations.
The estimated interest payments on the debt and the planned funding
for
pension and post-retirement benefit funding are summarized below.
It is
our intent, based on discussion with Gus Rodriguez, to ensure that
this
data is included in future filings.
Total
2005
2006
&
2007
2008
&
2009
After
5
Years
Interest
on Long-Term Debt
69.0
16.6
33.2
33.2
-
(1
)
Pension
Funding
136.4
45.0
91.4
-
-
(2
)
Post-Employment
Benefit Funding
46.1
14.2
31.9
-
-
(3
)
(1)
The
long-term debt matures in 2009. Interest payments are converted into
Canadian dollars based on $1 Cdn = $.83
U.S.
2
(2)
The
accuracy of this forecast of future cash flows depends on various
factors
such as actual return on plan assets, discount rates used to calculate
obligations, rate of compensation increases and mortality rates.
It is
impossible to make a prediction of cash requirements beyond the term
of
the USWA labour contracts which expire in 2007.
(3)
The accuracy of this forecast of future
cash
flows depends on various factors such as discount rates used to calculate
obligations, mortality rates and health escalation rates. It is impossible
to make a prediction of cash requirements beyond the term of the USWA
labour contracts which expire in 2007.
I
have also attached a statement from the Company acknowledging several conditions
as requested.
I
trust that this addresses the items raised in your letter.
Yours
truly,
ALGOMA
STEEL INC.
/s/
GLEN MANCHESTER
Glen
Manchester
Vice
President - Finance and
Chief
Financial Officer
GPM:all
Attachs.
STATEMENT
BY ALGOMA STEEL INC.
Algoma
Steel Inc. hereby certifies the following:
•
The
Company is responsible for the adequacy and accuracy of the disclosure
in
their filings;
•
The
Company acknowledges that staff comments or changes to disclosure
in
response to staff comments do not foreclose the Commission from taking
any
action with respect to the filing;
and
•
The
Company acknowledges that it cannot use SEC staff comments as a defense
in
any proceeding initiated by the Commission or any person under the
federal
securities laws of the United
States.
/s/
DENIS
TURCOTTE_______________________
Denis
Turcotte
President
and Chief
Executive Officer
/s/
GLEN
MANCHESTER_____________________
Glen
Manchester
Vice
President - Finance and Chief Financial
Officer