SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

June 5, 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 response letter  dated May 21, 2012 and have the
following additional comments.  If you disagree, we will consider your explanation as to
why our comment is inapplicable.  In some of our comments, we may ask you to provide
us with supplemental information so we may bett er understand your disclosure.  After
reviewing this information, we may or may not raise additional comments.  Form 10-K for the fiscal year ended December 31, 2011

 Note 17  Commitments and Contingencies, page 79

 1. We note your response to our prior c omment one.  We note that your
environmental managers have detailed kno wledge of each site where
environmental remediation and other environmental obligations are either known
or alleged.  We also note that the amounts recorded for environmental remediation obligations represent your be st estimate to complete the known work
required.  Given the specialized knowledge of your environmental managers and
third-party consultants and your abilit y to estimate costs to complete known work,
it is unclear to us why you cannot also estimate potential losses in excess of amounts accrued.  Please explain further .  In addition, we remind you that ASC
450 requires you to disclose whether reasonably possible losses in excess of
amounts accrued may be material to yo ur financial statements, not whether these
amounts may be material to a decision to buy or sell your securities.  Therefore,
please revise your disclosure in future filings to comply with the ASC 450
requirements.

Mr. Dale Reid
Allegheny Technologies Inc. June 5, 2012
Page 2

2. We note your response to our prior comme nt two.  It continues to be unclear to us
why you cannot estimate the amount of reasonably possible losses in excess of amounts accrued for your pending lawsuits, claims and proceedings.  Please explain further.  We again remind y ou that you are not required to estimate with
confidence or precision.  In addition, we note your intention to disclosure in
future filings that you believe the resolution of these matters would not be material to a decision to buy or sell your securities.  We remind you that ASC 450 requires you to disclose whether reasonably possible losses in excess of amounts
accrued may be material to your financ ial statements, not whether these amounts
may be material to a decision to buy or sell your securities.  Therefore, please revise your disclosure in future filings to comply with the ASC 450 requirements.

*    *    *    *

As appropriate, please respond to these c omments within 10 business days or tell
us when you will provide us with a response.  Please furnish a letter that keys your responses to our comments and provides any requested supplemental information.  Detailed response letters greatly facilitate our re view.  Please file your response letter on
EDGAR.  Please understand that we may have additional comments after reviewing your
responses to our comments.

You may contact Tricia Armelin at (202) 551 -3747 or me at (202) 551-3768 if
you have questions regar ding these comments.

Sincerely,
   /s/ John Cash
John Cash
        Accounting Branch Chief