United States securities and exchange commission logo





                              September 9, 2022

       Avner Applbaum
       Chief Financial Officer
       Valmont Industries, Inc.
       15000 Valmont Plaza
       Omaha, Nebraska 68154

                                                        Re: Valmont Industries,
Inc.
                                                            Form 10-K for
Fiscal Year Ended December 25, 2021
                                                            Response Dated
August 26, 2022
                                                            File No. 001-31429

       Dear Mr. Applbaum:

              We have reviewed your August 26, 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
       July 29, 2022 letter.

       Response Dated August 26, 2022

       Risk Factors, page 10

   1.                                                   Your response to prior
comment two states that technological changes related to climate
                                                        change manifest more as
opportunities than as risks, but it does not appear that your
                                                        response explains your
assessment of these risks. Please tell us about the risks related to
                                                        technological changes
you identified in your analysis and explain how you evaluated their
                                                        effect on your
business, financial condition, and results of operations. In addition, please
                                                        tell us about market
trends relevant to your business in the context of climate change,
                                                        including those that
could affect your competitive position in each of the markets that you
                                                        serve or that could
require a change in your business strategy.
 Avner Applbaum
FirstName LastNameAvner    Applbaum
Valmont Industries, Inc.
Comapany 9,
September NameValmont
             2022        Industries, Inc.
September
Page 2    9, 2022 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
21

2.       We note your response to prior comment four and reissue it in part.
Please tell us about
         and quantify your capital expenditures for climate-related projects
budgeted for future
         periods.
3.       We note your response to prior comment five. Please further address
the following items:

                Your response indicates that, beyond perceived increases in
product demand, you
              have not identified any other material business trends as
indirect consequences of
              climate-change regulations or business trends. Explain to us how
you evaluated the
              business trends you considered for each of the items noted in our
prior comment
              including causes of changes in demand for goods or services,
providing support for
              your determinations of materiality.

                Explain to us how you considered providing disclosure regarding
changes in demand
              for alternative energy sources in connection with reducing energy
use and fossil fuels
              across your operations.

                Your response describes increased demand for certain products
as an indirect
              consequence of climate-related regulation. Tell us how you
evaluated the materiality
              of these opportunities for purposes of disclosure.
4.       We note your response to prior comment six. Please further address the
following:

                As it relates to arability of farmland and agricultural
production capacity in areas
              affected by weather-related changes, please tell us how you
considered providing
              disclosure that addresses risks associated with climate change
that may arise from
              physical risks to entities other than yourself (for example, as
part of the risk factor
              disclosure on pages 10-11 of your Form 10-K regarding cyclicality
in the industries
              in which the ultimate consumers of your products operate).

                Quantify for us the cost of insurance for each of the periods
covered by your Form
              10-K.

       Please contact Erin Donahue at 202-551-6063 or Jennifer Angelini at
202-551-3047 with
any questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of
Manufacturing