Plum Creek Timber Company, Inc.
999 Third Avenue, Suite 4300
Seattle, WA 98104-4096
206-467-3600
February 15, 2008
Ms. Jennifer Gowetski, Attorney-Advisor
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
| Re: | Plum Creek Timber Company, Inc. Definitive 14A |
Dear Ms. Gowetski:
This letter is submitted on behalf of Plum Creek Timber Company, Inc. (“Plum Creek”) to confirm its intent to make certain disclosures in future filings that call for information required by Item 402 of Regulation S-K. Plum Creek’s confirmations are set forth below.
| 1. | You have asked us to confirm that we will disclose in our future filings the names of all the companies comprising any index, or subset thereof, used or referenced by the Compensation Committee in benchmarking any item of compensation for the named executive officers. |
Plum Creek hereby confirms that it will include in its future filings the names of the companies comprising any index, or subset thereof, used or referenced by the Compensation Committee in benchmarking any item of compensation for the named executive officers.
| 2. | You have asked us to confirm that we will disclose in future filings the Annual Incentive Plan performance target of funds from operations, or FFO, for the plan year requiring disclosure under Item 402 of Regulation S-K. |
Plum Creek hereby confirms that it will disclose in its future filings the Annual Incentive Plan FFO performance target for the plan year requiring disclosure under Item 402 of Regulation S-K.
If you have any questions regarding this matter, please contact Jose Quintana at (206) 467-3694.
| Sincerely, |
| /s/ Rick R. Holley |
| Rick R. Holley |
| President and Chief Executive Officer |
| Plum Creek Timber Company, Inc. |