Company Name: Occidental Petroleum Corp.
Public Availability Date: November 21, 2007

Document Sections:

INQUIRY LETTER
APPENDIX
STAFF REPLY LETTER

[INQUIRY LETTER]

October 4, 2007

VIA FEDERAL EXPRESS

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D. C. 20549

Re: Occidental Petroleum Corporation Omission of Stockholder Proposal

Ladies and Gentlemen:

Pursuant to Rule 14a-8(j) under the Securities Exchange Act of 1934, as amended (the "Exchange Act"), Occidental Petroleum Corporation, a Delaware corporation ("Occidental" or the "Company"), requests your concurrence that the stockholder proposal received by the Company from Mr. Robert Morse, attached hereto as Exhibit A (the "Proposal"), may properly be omitted from the proxy materials for the Company's 2008 Annual Meeting of Stockholders. The Proposal requests that the Board of Directors take action to limit remuneration of five highest-paid employees to $500,000 per year.

Occidental believes the proposal may be omitted under Rule 14a-8(f)(1) because Mr. Morse did not provide evidence of his eligibility to submit a proposal under within the 14-day deadline provided.

Subsection (b) of Rule 14a-8 provides that a stockholder who is not a record holder must provide proof of ownership of $2,000 in securities (or 1% of market value) for one year. Subsection (f) of Rule 14a-8 provides that, if a stockholder fails to follow one of the eligibility or procedural requirements in Rule 14a-8, the company may exclude the stockholder's proposal, but only after the company has notified the stockholder of the problem in writing within 14 calendar days of receipt of the proposal, and the stockholder has failed adequately to correct it. See General Motors (March 22, 2007).

Occidental received Mr. Morse's letter, dated August 30, 2007, on September 5, 2007. The cover letter accompanying Mr. Morse's proposal, which is attached hereto as Exhibit B, stated that TD Ameritrade held his stock in uncertificated form. Occidental informed Mr. Morse by letter, dated September 6, 2007 (attached hereto as Exhibit C), that we required proof of ownership such as a written statement from TD Ameritrade confirming his ownership of Occidental stock. The Company also informed him that, pursuant to subparagraphs (b) and (f) of Rule 14a-8, his confirmation must be postmarked or transmitted electronically within fourteen days of receipt of the September 6 letter.

The September 6 letter was delivered by Federal Express to Mr. Morse on September 7, 2007. The confirmation of delivery is attached hereto as Exhibit D. The deadline for Mr. Morse to provide evidence of stock ownership was September 21, 2007. As of this date, the company has not received any communication from Mr. Morse.

In accordance with Rule 14a-8(j), a copy of this letter is being sent to Mr. Morse with a letter from the Company notifying him of Occidental's intention to omit the Proposal from its proxy materials. A copy of that letter is enclosed as Exhibit E.

Also enclosed are six copies of this letter with exhibits and copies of the no-action letters referenced herein and an additional receipt copy of this letter. Please return the receipt copy in the enclosed self-addressed stamped envelope.

Occidental plans to begin mailing its proxy materials on or about March 20, 2008. Accordingly, we would appreciate receiving your response no later than March 13, 2008, in order to meet our printing schedule. If you have any questions concerning the Proposal or this request, please call the undersigned at (310) 443-6189.

Very truly yours,

/s/

Linda S. Peterson

Enclosures

cc: Mr. Robert Morse

[APPENDIX]

Exhibit A

Robert D. Morse
212 Highland Ave.
Moorestown, NJ 08957-2717
Ph: 856 235 1711

August 30, 2007

PROPOSAL

I, Robert D. Morse, of 212 Highland Avenue, Moorestown, NJ 08057-2717, owner of $2000.00 or more of Oceidental Petroleum Corp. stock, held for a year, request the Board of Directors to take action regarding remuneration to any of the top five persons named in Management be limited to $500,000.00 per year, by salary only, plus any nominal perks [i.e.; company car use, club memberships] This program is to be applied after any existing programs now in force for cash, options, bonuses, SAR's, etc., plus discontinue, if any, severance contracts, in effect, are completed, which I consider part of remuneration programs.

This proposal does not affect any other personnel in the company and their remuneration programs

REASONS

Ever since about Year 1975, when "Against" was removed from "Vote for Directors" box, and no other on the Proxy Vote, and the term "Plurality" voting was contrived, shareowners have lost the "Right of Dissent", which is unconstitutional. No reason given, but the result has been that any Management nominee for Director was elected, even if only one "For" vote was received. This is because "Abstain" and "Withheld" are not deducted from "For". In response, Directors have awarded remuneration to those whom nominated them, to the point of being excessive and still escalating. Millions of dollars of shareowners assets are diverted for the five top Management, year after year, until their retirement or they "Jump Ship" for another company's offer. It is seldom proven to have been "earned" by their efforts, rather than the product or services.

The limit of one half million dollars in remuneration is far above that needed to enjoy an elegant lifestyle. These funds might better be applied to dividends. The savings in elimination of personnel needed to process all previous programs could be tremendous. Plus savings on lengthy pages reporting the process in the Report, a help for the National Paperwork Reduction Act.

This can all be accomplished by having Directors eliminate all Rights, Options, S.A.R.'s, retirement and severance, etc. programs, relying on $500,000.00 to be adequate, and Management buying their own stock and retirement programs, if desired.

It is commendable that AT&T, ExxonMobil, Ford Motor [1\st/], perhaps others, have already returned "Against" as requested.

Thank you and please vote "YES" for this Proposal. It is for Your benefit!

Robert D. Morse

/s/

[STAFF REPLY LETTER]

November 21, 2007

Response of the Office of Chief Counsel Division of Corporation Finance

Re: Occidental Petroleum Corporation Incoming letter dated October 4, 2007

The proposal relates to compensation.

There appears to be some basis for your view that Occidental may exclude the proposal under rule 14a-8(f). We note that the proponent appears not to have responded to Occidental's request for documentary support indicating that the proponent has satisfied the minimum ownership requirement for the one-year period required by rule 14a-8(b). Accordingly, we will not recommend enforcement action to the Commission if Occidental omits the proposal from its proxy materials in reliance on rules 14a-8(b) and 14a-8(f).

Sincerely,

/s/

Ted Yu
Special Counsel