SecProbe.io

May 10, 2012
 Via E-mail

Mr. Dale Reid Chief Financial Officer Allegheny Technologies Inc. 1000 Six PPG Place Pittsburgh, PA 15222-5479
Re: Allegheny Technologies Inc.
 Form 10-K for the fiscal year ended December 31, 2011
Filed February 27, 2012 File No. 1-12001

Dear Mr. Reid:
 We have reviewed your filing 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 this letter within ten business days by amending your filing, by
providing the requested information, or by advi sing us when you will provide the requested
response.  If you do not believe our comments apply to your fact s and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.  Form 10-K for the fiscal year ended December 31, 2011

 Note 17  Commitments and Contingencies, page 79

1. We note your disclosure that your environmen tal matters could have a material adverse
effect on your financial condition or results of operations.  Pleas e revise future filings to
disclose your reasonably possible loss or range of loss in excess of amounts accrued.  If
you conclude that you cannot estimate the r easonably possible loss or range of loss
please: (1) explain to us th e procedures you undertake on a qu arterly basis to attempt to
develop an estimate disclosure and (2) what specific factors are causing the inability to
estimate and when you expect those factors to be  alleviated.  We rec ognize that there are
a number of uncertainties and potential outcome s associated with loss contingencies.
Nonetheless, an effort should be made to de velop estimates for purposes of disclosures,
including determining which of the potentia l outcomes are reasonably possible and what

Mr. Dale Reid Allegheny Technologies Inc. May 10, 2012 Page 2

 the reasonably possible range of losses woul d be for those reasona bly possible outcomes.
We remind you that ASC 450 does not require es timation with confidence or precision.

2. We note your disclosure that the dispositi on of your pending lawsuits, claims and
proceedings could have a material adverse effect on your results of operations.  Please
revise future filings to disclo se your reasonably possible loss or  range of loss in excess of
amounts accrued.  If you conclude that you canno t estimate the reasonably possible loss
or range of loss please: (1) explain to us  the procedures you u ndertake on a quarterly
basis to attempt to develop an estimate di sclosure and (2) what specific factors are
causing the inability to estimate and when you e xpect those factors to be alleviated.  We
recognize that there are a number of uncertain ties and potential outcomes associated with
loss contingencies.  Nonetheless, an effort  should be made to develop estimates for
purposes of disclosures, incl uding determining which of the potential outcomes are
reasonably possible and what th e reasonably possible range of losses would be for those
reasonably possible outcomes.  We remind you that ASC 450 does not require estimation
with confidence or precision.  Disclosure may be provided on an aggregated basis.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;

 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 may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

You may contact Tricia Arme lin at (202) 551-3747 or me at (202) 551-3768 if you have
questions regarding these comments.
Sincerely,
   /s/ John Cash
John Cash
        A c c o u n t i n g  B r a n c h  C h i e f