116 Huntington Avenue

Boston, MA 02116

September 2, 2009

FOIA CONFIDENTIAL TREATMENT REQUESTED

BY OVERNIGHT DELIVERY AND EDGAR

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Mailstop–3720

Washington, D.C. 20549

Attention:	Larry Spirgel
	Robert S. Littlepage, Jr.
	Melissa Hauber

Re:	American Tower Corporation
	Form 10-K for Fiscal Year Ended December 31, 2008
	Filed February 26, 2009
	File No.: 1-14195
	Form 10-Q for Fiscal Quarter Ended March 31, 2009
	Filed May 8, 2009
	File No.: 1-14195

Ladies and Gentlemen:

On behalf of American Tower Corporation (“American Tower” or the “Company”), this letter provides a summary of information orally requested by the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) by telephone conversation on August 31, 2009. That telephone conversation concerned the materials submitted by the Company to the Staff on August 27, 2009 (the “Materials”) to supplement the Company’s letter dated July 15, 2009 responding to comments submitted by the Staff in a letter dated July 1, 2009 (the “Letter”) relating to American Tower’s Annual Report on Form 10-K for the year ended December 31, 2008 (the “Form 10-K”) and Quarterly Report on Form 10-Q for fiscal quarter ended March 31, 2009 (the “Form 10-Q”). For your convenience, the Company has briefly summarized what the Company understands to be the substance of the Staff’s oral request, followed by the Company’s response.

Confidential Treatment Requested by American Tower Corporation

ATC-001

[* * *] – Information omitted and provided under separate cover to the Staff pursuant to Rule 83

As we continue to address the Company’s responses to our comments submitted in the Letter and upon initial review of the Materials, we would like to obtain the complete KPMG LLP valuation report dated as of January 31, 2007 (the “Report”).

RESPONSE:

In response to the Staff’s request, the Company has attached as Appendix A the complete Report.

*    *    *    *

In submitting this response, the Company acknowledges that:

• the Company is responsible for the adequacy and accuracy of the disclosure in the filings;

• Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filings; and

• the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you require additional information, please telephone the undersigned at (617) 375-7500.

Very truly yours,

/s/ Edmund DiSanto

Edmund DiSanto

Executive Vice President, Chief Administrative

Officer, General Counsel and Secretary

cc:	Thomas A. Bartlett
	Michael John McCormack, Esq.
	Mneesha O. Nahata, Esq.
	American Tower Corporation
	Thomas V. Milbury
	Deloitte & Touche LLP
	Sandra L. Flow, Esq.
	Cleary Gottlieb Steen & Hamilton LLP

Confidential Treatment Requested by American Tower Corporation

ATC-002

[* * *] – Information omitted and provided under separate cover to the Staff pursuant to Rule 83

Appendix A

[* * *]

Confidential Treatment Requested by American Tower Corporation

ATC-003

[* * *] – Information omitted and provided under separate cover to the Staff pursuant to Rule 83