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United States securities and exchange commission logo
July 1, 2022
Alan J.M. Haughie
Chief Financial Officer
Louisiana-Pacific Corporation
414 Union Street, Suite 2000
Nashville, Tennessee 37219
Re: Louisiana-Pacific
Corporation
Form 10-K for
Fiscal Year Ended December 31, 2021
Response Dated June
10, 2022
File No. 001-07107
Dear Mr. Haughie:
We have reviewed your June 10, 2022 response to our comment
letter 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 these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
June 3, 2022 letter.
Response Dated June 10, 2022
Risk Factors, page 13
1. We note from your
response to comment 2 that transition risks related to climate change
did not have a material
impact on you. Tell us more about the transition risks you have
identified related to
climate change, such as market trends that may alter business
opportunities, credit
risks, or technological changes, and explain how you concluded that
they are not material
to your business, financial condition, and results of operations.
Management's Discussion and Analysis of Financial Condition and Results
of Operations, page
27
2. We note your response
to comment 5 that you have not identified any material indirect
consequences of
climate-related regulation or business trends. Please describe the indirect
Alan J.M. Haughie
Louisiana-Pacific Corporation
July 1, 2022
Page 2
consequences of climate change you considered in preparing the
disclosure in your Form
10-K along with those noted in our prior comment and explain how you
concluded they
were not material.
3. We note your response to comment 6 and reissue in part. Discuss the
physical effects of
climate change on your operations and results, including the potential
for indirect weather-
related impacts that have affected or may affect your major customers
or suppliers or
explain to us why you do not believe they could potentially be
affected, and discuss any
weather-related impacts on the availability of insurance and future
expectations for
insurance expense.
4. We note your response to comment 7 that it is not feasible to specify
the amount of
compliance costs relating to climate change, but such costs are not
material, individually
or in the aggregate. Provide us with additional detail of how you
concluded such amounts
were not material.
Please contact Patrick Fullem at (202) 551-8337 or Sergio Chinos at
(202) 551-7844 with
any questions.
FirstName LastNameAlan J.M. Haughie Sincerely,
Comapany NameLouisiana-Pacific Corporation
Division of
Corporation Finance
July 1, 2022 Page 2 Office of
Manufacturing
FirstName LastName