SecProbe.io

Mail Stop 4561
         March 31, 2008
Mr. Hans E. Vanden Noort Senior Vice President and Chief Financial Officer Rayonier Inc. 50 North Laura Street Jacksonville, FL 32202

Re: Rayonier Inc.
  Form 10-K for the year ended December 31, 2007
  Filed February 28, 2008   File No. 1-06780

Dear Mr. Vanden Noort:
We have reviewed your filing and have the following comments.  Where
indicated, we think you should revise your document in future filings in response to these comments.  If you disagree, we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Pl ease be as detailed as necessary in your
explanation.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.  After reviewing this information, we may
raise additional comments.
Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our comments or any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 Notes to Consolidated Financial Statements, page F-7

 Note 2 – Summary of Significant Accounting Policies, page F-8

1. You disclose your accounting policy is to expense environmental costs related to
ongoing businesses resulting from current op erations and accrue liabilities related
to dispositions or discontinued operati ons.  Please tell us whether you have
identified any environmental remedi ation obligations related to ongoing
businesses and whether you have accrued fo r such liabilities in accordance with
paragraph 9 of SFAS 5.

Mr. Hans E. Vanden Noort
Rayonier Inc.
March 31, 2008 Page 2
2. Please indicate in future filings whet her you accrue for environmental liabilities
on a discounted or undiscounted basis.  To  the extent that you utilize present-
value measurement techniques, disclose at  a minimum the discount rate used, the
expected aggregate undiscounted amount, expe cted payments for each of the five
succeeding years and the aggregate amount th ereafter, and a reconciliation of the
expected aggregate undiscounted amount to amounts recognized in the balance sheet.  For reference see SAB Topic 5:Y.

*****

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please  understand that we may have additional
comments after reviewing your responses to our comments.

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that:
• the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;

• 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Mr. Hans E. Vanden Noort
Rayonier Inc. March 31, 2008 Page 3
 In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filings or in response to our comments on your filing.
You may contact Jonathan Wiggins at ( 202) 551-3694 or me at (202) 551-3486 if
you have questions regarding comments on the financial statements and related matters.
          S i n c e r e l y ,
Daniel L. Gordon  Branch Chief