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United States securities and exchange commission logo
June 3, 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
Filed February 22,
2022
File No. 001-07107
Dear Mr. Haughie:
We have reviewed your filing 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.
Form 10-K filed February 22, 2022
General
1. We note that you
provided more expansive disclosure in your 2021 Sustainability Report
and on your company
website than you provided in your SEC filings. Please advise us
what consideration you
gave to providing the same type of climate-related disclosure in
your SEC filings as you
provided in your 2021 Sustainability Report and on your
company website.
Risk Factors, page 13
2. It appears that you
have identified transitioning to a lower-carbon economy as a
transition risk related
to climate change. Revise to provide expanded disclosure that more
clearly describes the
material effects of transition risks related to climate change that may
affect your business,
financial condition, and results of operations, such as policy and
regulatory changes that
could impose operational and compliance burdens, market trends
Alan J.M. Haughie
FirstName LastNameAlan J.M. Haughie
Louisiana-Pacific Corporation
Comapany
June 3, 2022NameLouisiana-Pacific Corporation
June 3,
Page 2 2022 Page 2
FirstName LastName
that may alter business opportunities, credit risks, or technological
changes.
3. Disclose any material litigation risks related to climate change and
explain the potential
impact to the company.
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
27
4. Revise your disclosure to identify any material past and/or future
capital expenditures for
climate-related projects. Please include quantitative information for
the periods covered
by your Form 10-K and for future periods as part of your response.
5. To the extent material, discuss the indirect consequences of
climate-related regulation or
business trends, such as the following:
decreased demand for goods or services that produce significant
greenhouse gas
emissions or are related to carbon-based energy sources;
increased demand for goods that result in lower emissions than
competing products;
increased competition to develop innovative new products that
result in lower
emissions;
increased demand for generation and transmission of energy from
alternative energy
sources;
any anticipated reputational risks resulting from operations or
products that produce
material greenhouse gas emissions; and
any new climate-related opportunities, such as carbon-negative
products.
6. We note your disclosure that global climate change may increase the
frequency or
intensity of extreme weather events that could affect your facilities
and demand for your
products. If material, discuss the physical effects of climate change
on your operations
and results. This disclosure may include the following:
quantification of material weather-related damages to your
property or operations;
potential for indirect weather-related impacts that have affected
or may affect your
major customers or suppliers;
decreased production capacity or reduced supply of raw materials
in areas affected by
drought or other weather-related changes; and
any weather-related impacts on the cost or availability of
insurance.
Include quantitative information for each of your last three fiscal
years as part of your
response and tell us whether changes are expected in future periods.
7. We note the disclosure on page 18 of your Form 10-K that you have
incurred and expect
to incur significant expenditures to comply with applicable
environmental laws and
regulations. Tell us about and quantify compliance costs related to
climate change for
each of the periods covered by your most recent Form 10-K and whether
increased
amounts are expected to be incurred in future periods.
8. If material, provide disclosure about your purchase or sale of carbon
credits or offsets and
any material effects on your business, financial condition, and
results of operations.
Alan J.M. Haughie
Louisiana-Pacific Corporation
June 3, 2022
Page 3
Include quantitative information regarding any such transactions
during the last three
years and subsequent periods as part of your response.
We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.
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
June 3, 2022 Page 3 Office of
Manufacturing
FirstName LastName