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Mailstop 3233
November 17, 2015

VIA E -MAIL
Mr. Allen E. Lyda
Chief Financial Officer
Tejon Ranch Co.
P.O. Box 1000
Lebec, California 93243

Re: Tejon Ranch Co.
Form 10-K for Fiscal Year Ended December 31, 2014
Filed on March 16, 2015
File No. 001-07183

Dear Mr. Lyda :

We have reviewed your filing an d 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 busine ss days by providing the requested
information or advis e 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 for the fiscal year ended December 31, 2014

General

1. In future Exchange Act periodic reports, please describe how you monitor tenant credit
quality and identify any mate rial changes in quality.

Item 1. Business, page 4

Real Estate Operations, page 6

2. In future Exchange Act periodic reports, and to the extent you have a material
development portfolio, please disclose anticipated completion dates, costs incurred to
date a nd estimated costs to completion for each of your developments.

Mr. Allen E. Lyda
Tejon Ranch Co.
November 1 7, 2015
Page 2

Customers, page 10

3. We note your disclosure that no customer represented 10% of more of your revenues in
2014.   In future Exchange Act periodic reports, to the extent any of your leaseholders
represent 5% or more of your revenues, please disclose your tenant concentration.

Item 2. Properties, page 16

4. We note that you lease land to various types of tenants.   In future Exchange Act periodic
reports, please include a schedule of the  lease expirations for each of the ten years
starting with the year in which the annual report is filed, stating (i) the number of tenants
whose leases will expire, (ii) the total area of square feet covered by such leases (or other
appropriate metric), (i ii) the annual rental represented by such leases, and (iv) the
percentage of gross annual rental represented by such leases.

5. In future Exchange Act periodic reports, to the extent material and known by
management, please include disclosure that addresses the relationship between rates on
leases expiring in the current year and current market rents for this space.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations, page 22

6. In future Exchange Act periodic reports,  please compare new rents on renewed leases to
prior rents, as adjusted for free rent periods.

Item 15(a)(1) – Financial statements, page 49

Notes to consolidated financial statements, page 58

Note 8. Line -of-credit and long -term debt, page 68

7. Please revise future periodic filings to include the disclosures for long term obligations
outlined within paragraph 470 -10-50-1 of the Financial Accounting Standards
Codification.

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 the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the compa ny and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, please provide  a written statement from the co mpany
acknowledging that:

Mr. Allen E. Lyda
Tejon Ranch Co.
November 1 7, 2015
Page 3

 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 filing; 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.

You may contact Peter McPhun, Staff Accountant , at 202-551-3581 or me at 202 -551-
3468  if you have questions regarding comments on the financial statements and related matters.
Please contact Sandra Hunter, Staff Attorney , at 202-551-3758  or Kim McManus at 202-551-
3215  with any other questions.

Sincerely,

  /s/ Wilson K. Lee

Mr. Wilson K. Lee
Senior Staff Accountant
Office of Real Estate and
Commodities