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1000 Six PPG Place

Pittsburgh, PA 15222-5479

June 8, 2010

Via EDGAR and Facsimile

United States Securities and Exchange Commission

Division of Corporation Finance

100 F. Street N.E.

Washington, D.C. 20549-7010

Attn: Ms. Tracey McKoy

    RE:

    Allegheny Technologies Incorporated

    Form 10-K for the fiscal year ended December 31, 2009

               Filed February 25, 2010

    File No. 1-12001

Dear Ms. McKoy:

          This letter sets forth our response to the letter dated May 25, 2010 from the Staff of the
Securities and Exchange Commission with respect to the Form 10-K for the year ended December 31,
2009 (the “Comment Letter”) of Allegheny Technologies Incorporated (the “Company”).

          Set forth below is the Company’s response to the comment set forth in the Comment Letter. For
your convenience, the comment is reproduced in bold text below and is followed by the Company’s
response.

Definitive Proxy Statement on Schedule 14A

General

1. We note that you do not have any disclosure indicating that your compensation policies and
practices for its employees are reasonably likely to have a material adverse effect on you. Please
advise us of the basis for your conclusion under Item 402(s) of Regulation S-K that disclosure is
not necessary and describe for us the process you undertook to reach that conclusion.

          In connection with the preparation of the Proxy Statement, the Company determined that the
risks arising from our compensation policies and practices are not reasonably likely to have a
material adverse effect on us. Item 402(s) of Regulation S-K calls for disclosure “[t]o the extent

Ms. Tracey McKoy

U.S. Securities and Exchange Commission

June 8, 2010

Page 2 of 4

that risk arising from the registrant’s compensation policies and practices for its employees are
reasonably likely to have a material adverse effect on the registrant . . . .” The Staff noted in
Release No. 33-9089, which adopted Item 402(s), that “a company may under appropriate circumstances
conclude that its compensation policies and practices are not reasonably likely to have a material
adverse effect on the company.” The Staff also stated in Release No. 33-9089, “We believe an
approach consistent with our prior practice is appropriate and the final rule does not require a
company to make an affirmative statement that it has determined that the risks arising from its
compensation policies and practices are not reasonably likely to have a material adverse effect on
the company.”

          In determining that the risks arising from our compensation policies and practices are not
reasonably likely to have a material adverse effect on us, our Personnel and Compensation Committee
of the Board of Directors (the “Committee”) reviewed the fundamental objectives of our compensation
policies and practices to determine whether any of the elements of our compensation programs
encourage excessive or inappropriate risk-taking. The Committee’s review considered not only the
compensation practices and levels with respect to named executive officers but also a review of the
compensation structure and variable compensation levels and performance criteria for salaried
employees generally as illustrated by the pyramid graphic in our Proxy Statement. No salaried
employee is given incentives to take risks that are reasonably likely to have a material adverse
effect on the Company or its business because variable compensation is not only capped but is based
on a number of performance criteria. In connection with its review, the Committee considered the
following factors, among others, related to the Company’s compensation policies and practices that
are intended to mitigate risk:

          •   The Committee has retained a compensation consultant to assist in the analysis of
certain comparative market data of a selected peer group of companies and a wider group of
industrial companies. With primary reliance on the peer group, and using information about the
wider group of companies as a check against the peer group information, this “benchmarking” process
assists the Committee with assessing the competitiveness of the Company’s programs and earnings
opportunities relative to, as well as determining the approaches to compensation used by, the peer
companies and other industrial enterprises. The Committee has concluded that our compensation
programs and levels are generally competitive with those offered by companies within our peer group
and other industrial companies.

          •   The Company offers our named executive officers a balanced and diverse mix of
cash, equity and longer-term incentive compensation.

          •   The overall compensation of our named executive officers is not overly-weighted
towards the achievement of performance criteria in a particular fiscal year and an appropriate
portion of compensation is linked to our long-term performance, over a three- or possibly five-year
period.

Ms. Tracey McKoy

U.S. Securities and Exchange Commission

June 8, 2010

Page 3 of 4

          •  Our annual cash incentive program, which is our Annual Incentive Plan (“AIP”), has
payouts at multiple levels of performance rather than an “all-or-nothing” approach. The target
opportunities available to our named executive officers as a percentage of their base salaries are
capped to protect against disproportionately large shorter-term incentives.

          •  Payouts under our AIP are based on achievement of a diverse mix of performance
measures such as operating earnings, operating cash flow, manufacturing improvements, employee
safety, environmental compliance and responsiveness to customers. The Committee believes this
broad spectrum of performance measures coupled with relative weighting precludes excessive risk
taking in the AIP.

          •  Payouts under our long-term incentive programs, our Performance/Restricted Stock
Program (“PRSP”) and our Key Executive Performance Plan, are based on performance criteria that the
Committee believes to be challenging yet reasonable and attainable without excessive risk-taking.
The opportunities available to our named executive officers under these programs, as well as under
our Total Shareholder Return Incentive Compensation Program (“TSRP”), are also capped.
Furthermore, the TSRP measures returns to our shareholders relative to the shareholder returns of
an identified peer group, which essentially rewards building shareholder value. The payouts for
the PRSP and TSRP are made in stock, further aligning the interests of the named executive officers
with building long-term shareholder value. These long-term programs promote the alignment of the
interests of our named executive officers with those of our shareholders using a variety of
measurements to determine the level of achievement of that goal.

          •  The Committee periodically reviews interim performance data against program
performance goals as well as the Company’s business plan with a view towards identifying progress
toward achieving Company goals.

          •  We have established internal controls and standards of ethics and business conduct,
all of which variously help support our compensation goals and mitigate compensation risk.

          •  The payment of awards under our AIP is conditioned on adherence to the Company’s
Corporate Guidelines for Business Conduct and Ethics, which addresses various legal and ethical
issues and helps discourage imprudent risk-taking.

          •  The Committee generally has discretion to adjust annual incentive compensation awards
under our AIP downward based on performance.

          •  The Committee has included clawback provisions in each of our compensation programs
that require participants in plans to return compensation to the extent that earnings or other
performance measures are improperly reported.

Ms. Tracey McKoy

U.S. Securities and Exchange Commission

June 8, 2010

Page 4 of 4

          Based on these and other factors, the Committee concluded, and continues to believe, that our
compensation policies and practices encourage behaviors that are aligned with our long-term
interests. The Committee also concluded that our compensation policies and practices that involve
short-term incentives do not comprise a disproportionate portion of the compensation of our named
executive officers or other employees and do not encourage our employees to take undue risks for
short-term gain. As a result, the Committee determined that any risks arising from our
compensation policies and practices are not reasonably likely to have a material adverse effect on
the Company. In the future, if the Committee determines that any risks arising from our
compensation policies and practices for our employees are reasonably likely to have a material
adverse effect on us, we will include an appropriate disclosure in applicable future filings.

Please contact the undersigned at (412) 394-2836 with any questions or comments.

Very truly yours,

/s/ Jon D. Walton

Jon D. Walton

Executive Vice President, Human

Resources, Chief Legal and

Compliance Officer, General

Counsel and Corporate Secretary

cc: L. Patrick Hassey