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                             December 13, 2022

       Nelli Galeeva
       Deputy Chief Executive Officer for Finance
       Mechel PAO
       Krasnoarmeyskaya Street 1
       Moscow 125167
       Russian Federation

                                                        Re: Mechel PAO
                                                            Form 20-F for the
Year Ended December 31, 2021
                                                            Response Dated
November 1, 2022
                                                            File No. 1-32328

       Dear Nelli Galeeva:

              We have reviewed your November 1, 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
       September 12, 2022 letter.

       Form 20-F for the Year Ended December 31, 2021

       Mining Segment, page 68

   1.                                                   We note your response
to comment 1 stating your coal and iron ore mines are material to
                                                        your company. Please
amend your filing and include a statement indicating those mines
                                                        that are material to
your company.
       Mineral Resources, page 87

   2.                                                   We note your response
to comment 2 along with your summary of your resources
                                                        exclusive of reserves
and your point of reference. Please amend your filing and exhibits
                                                        to restate your
resources exclusive of reserves and state a point of reference for your
                                                        resource tonnage, such
as in-situ or in-place, Run-of-Mine (ROM), Mill Feed, or Clean
 Nelli Galeeva
FirstName  LastNameNelli Galeeva
Mechel PAO
Comapany13,
December   NameMechel
              2022      PAO
December
Page  2   13, 2022 Page 2
FirstName LastName
         Coal as is appropriate to your resource disclosure.
3.       We note your response to comment 3 indicating the Uvatskoye and
Pugachev quarries are
         not material. Summary disclosure requires resource and reserve
disclosure for all
         properties, material and otherwise. Please amend your filing and
report your resources
         and reserves for your Uvatskoye quarry. In addition, please provide an
explanation
         regarding the Pugachevsky non-compliant resources and reserves.
Mineral Resources, page 89

4.       We note your response to comment 4, disclosing the cut-off grades for
your iron ore
         assets. Please amend your resource and reserve disclosure in your
filing and exhibits to
         report your iron ore cutoff grades, the expected metallurgical
recovery, and the assumed
         operating costs used to calculate these cutoff grades.
Disclosure Controls and Procedures, page 223

5.       In light of the revisions to disclosures in your filing and related
technical reports to
         comply with Item 1300 of Regulation S-K, please re-assess your
conclusion that your
         disclosure controls and procedures were effective as of December 31,
2021.
Exhibits 15.1, 15.2, 15.3, and 15.4
Location and Access, page ES-1

6.       We note your response to comment 12 stating your enclosed maps contain
the required
         information. Please amend your exhibits' text to include each
properties location using a
         common coordinate system, such as latitude/longitude, and include the
appropriate maps
         with labeled coordinate lines.
Exhibits 15.1, 15.2, 15.3, and 15.4
Geology Local, page ES-2

7.       We note your response to comment 13 stating your enclosed
cross-sections and
         stratigraphic columns contain the required information. Please amend
your exhibits to
         ensure the representative cross-sections and stratigraphic columns for
each of your mines
         is included in the appropriate technical report.
Exhibits 15.1, 15.2, 15.3, and 15.4
Exploration and Drilling, page ES-3

8.       We note your response to comment 14 stating your plan maps with
drillhole locations
         contain the required information. Please amend your exhibits to ensure
the plan maps
         with drillhole locations for each of your mines is included in the
appropriate technical
         report. Please include coordinate lines and labels.
Exhibits 15.1, 15.2, 15.3, and 15.4
Sampling and Analytical Test work, page ES-4
 Nelli Galeeva
FirstName  LastNameNelli Galeeva
Mechel PAO
Comapany13,
December   NameMechel
              2022      PAO
December
Page  3   13, 2022 Page 3
FirstName LastName


9.       We note your response to comment 15 stating the sampling sections of
your technical
         reports disclose sampling information and that you have also provided
information
         regarding sampling for the Sivaglinskoye iron ore deposit. We re-issue
comment 15.
         Please amend your exhibits to describe your methods of sample
collection and sample
         preparation prior to analysis for your exploration programs. Please
provide the Qualified
         Persons    Opinion on your sample collection, sample preparation,
sample security, and
         your Quality Assurance (QA), and Quality Control (QC) for your
sampling programs.
Exhibits 15.1, 15.2, 15.3, and 15.4
Geological Data and Verification, page ES-5

10.      We note your response to comment 16 regarding the data verification
procedures along
         with the Qualified Persons    Opinion for the Yakutugol Holding
Company, Southern
         Kuzbass Coal Company, and Korshunov Mining Plant. The information you
have
         provided appears to more appropriately address comment 17
(Metallurgical Testing for
         exploration samples) rather than the audit/review of the analytical
and location
         information followed by the construction of the drillhole database. We
re-issue comment
         16. Please amend your exhibits to provide a description of your data
verification
         procedures and include the Qualified Persons    Opinion regarding
these data verification
         procedures.
Exhibits 15.1, 15.2, 15.3, and 15.4
Mineral Processing and Testing, page ES-6

11.      We note your response to comment 17 indicating the Yakutugol Holding
Company,
         Southern Kuzbass Coal Company, and Korshunov Mining Plant do not
conduct
         metallurgical testing and you have included the procedures used to
assess your operation   s
         metallurgical controls. As noted in the previous comment, the
information you provided
         for comment 16 appears to address this comment (Metallurgical Testing
for exploration
         samples) rather than data verification. Please amend your exhibits,
combining your
         responses to comments 16 and 17, providing a description of your
metallurgical testing for
         your exploration samples and sample assessment for your plant   s
operational control. In
         addition, please include the Qualified Persons    Opinion regarding
this metallurgical
         testing.
Exhibits 15.1, 15.2, 15.3, and 15.4 A
Resource Estimation, page ES-7

12.      We note your response to comment 18, providing a summary of your
resources excluding
         reserves. Please amend your exhibits, restating your resources
exclusive of reserves,
         disclosing all assumptions, cutoff grades, commodity prices, and
metallurgical recoveries
         used to estimate your resources as footnotes to your resource tables,
and include the
         Qualified Persons    opinion regarding the resource estimate.
 Nelli Galeeva
FirstName  LastNameNelli Galeeva
Mechel PAO
Comapany13,
December   NameMechel
              2022      PAO
December
Page  4   13, 2022 Page 4
FirstName LastName
Exhibits 15.1, 15.2, 15.3, and 15.4 A
Reserves Estimation, page ES-8

13.      We note your response to comment 19 indicating the assumptions and
forecasts were valid
         as of the date of the report. Please amend your exhibits, stating your
assumptions, the
         cutoff grade, commodity price, metallurgical recovery and other
modifying factors used to
         estimate your reserves. In addition, provide the Qualified Persons
opinion on how the
         mineral reserve estimates could be materially affected by risk factors
associated with or
         changes to any aspect of the modifying factors.
Exhibits 15.1, 15.2, 15.3, and 15.4 A
Mining Operations, page ES-9

14.      We note your response to comment 20 stating your Qualified Persons
opinion regarding
         the company   s plans for production and sales. Please amend your
exhibits to state your
         Qualified Persons    opinion in the appropriate section of your
technical reports.
Exhibits 15.1, 15.2, 15.3, and 15.4 A
Sales and Marketing, page ES-10

15.      We note your response to comment 21 indicating your forecast prices
and specifications.
         Please amend your exhibits, stating your sources/authors and dates for
your forecast prices
         and provide the specifications for your major products in the
marketing section.
Exhibits 15.1, 15.2, 15.3, and 15.4 A
Costs, page ES-11

16.      We note your response to comment 22 stating the process you used to
estimate your
         operating and capital costs. Please amend your exhibits to state your
methodology for
         preparing your cost estimates, and provide an estimate of the accuracy
of your capital
         & operating cost estimates or state separately, the operating cost and
capital costs are
         sufficiently accurate to prepare a preliminary feasibility study.
Exhibits 15.1, 15.2, 15.3, and 15.4 A
Economic Analysis, page ES-12

17.      We note your response to comment 23, describing some of the
assumptions for your cash
         flow tables. Please amend your exhibits to include your assumptions
and annual cash
         flow for each year with rows for production, salable product
quantities, revenues, major
         cost centers, taxes, royalties, capital, and final closure costs and
net after tax cash flow.
Exhibits 15.1, 15.2, 15.3, and 15.4 B
Methodology and Assumptions, page ES-13

18.      We note your response to comment 24, stating your Qualified Person has
given and not
         withdrawn its written consent. Disclaimers are not permitted. Please
amend your exhibits
 Nelli Galeeva
Mechel PAO
December 13, 2022
Page 5
         to remove all disclaimers from your filing.
       You may contact Ken Schuler at (202) 551-3718 or Craig Arakawa at (202)
551-3650
with any mining related questions. You may contact Mindy Hooker at (202)
551-2732 or Anne
McConnell at (202) 551-3709 with any other questions.



FirstName LastNameNelli Galeeva                         Sincerely,
Comapany NameMechel PAO
                                                        Division of Corporation
Finance
December 13, 2022 Page 5                                Office of Manufacturing
FirstName LastName