Company Name: Pulte Homes, Inc.
Public Availability Date: February 11, 2008

Document Sections:

INQUIRY LETTER
INQUIRY LETTER
INQUIRY LETTER
INQUIRY LETTER
APPENDIX
STAFF REPLY LETTER

[INQUIRY LETTER]

December 28, 2007

By Federal Express

U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Chief Counsel
100 F Street, N.E.
Washington, D.C. 20549

Re: Omission of Shareholder Proposal Submitted by The Nathan Cummings Foundation and Co-Filers

Ladies and Gentlemen:

We are counsel to Pulte Homes, Inc. ("Pulte" or the "Company") and, on behalf of Pulte, we respectfully request that the staff of the Division of Corporation Finance (the "Staff") concur that it will not recommend enforcement action if Pulte omits a shareholder proposal and supporting statement (the "Proposal") submitted by The Nathan Cummings Foundation, together with Domini Social Investments, Providence Trust, the General Board of Pension and Health Benefits of the United Methodist Church and SEIU Master Trust (collectively, the "Proponents") for the reasons set forth below. The Proponents seek to include the Proposal in Pulte's proxy materials for the 2008 annual meeting of shareholders (the "2008 Proxy"). The Proposal requests that Pulte's Board of Directors provide to shareholders a climate change report on the feasibility of developing policies that will minimize Pulte's impacts upon climate change, with a focus on reducing greenhouse gas emissions from Pulte's products and operations.

Pulte received copies of the Proposal from the Proponents dated November 26, 2007, November 29, 2007, November 30, 2007, December 4, 2007 and December 5, 2007, respectively. Pursuant to Rule 14a-8(j), Pulte is submitting six paper copies of the Proposal and an explanation as to why Pulte believes that it may exclude the Proposal from the 2008 Proxy. A copy is being submitted to each of the Proponents simultaneously. For your review, we have attached a copy of the entire Proposal as Appendix A. Pulte appreciates the Staff's consideration and time spent reviewing this no action request.

For purposes of our discussion, a key portion of the Proposal reads as follows:

With residential end-use accounting for such a high proportion of GHG emissions stemming from fossil fuel combustion, a number of recent studies have focused on energy efficiency improvements in residential dwellings as a potential source of emission reductions. .... A second McKinsey study concluded that the residential sector represents the single-largest opportunity to raise energy productivity, noting that, "The adoption of available technologies (including high-efficiency building shells, compact fluorescent lighting, and high-efficiency water heating) would cut ... end-use demand for energy by 32 QBTUs in 2020, equivalent to 5 percent of global end-user demand in that year."

Resolved:

Shareholders request that by December 31, 2008 the Board of Directors provide a climate change report, prepared at reasonable cost and omitting proprietary information, on the feasibility of our company developing policies that will minimize its impacts upon climate change, with a focus on reducing greenhouse gas emissions from the company's products and operations.

As described below, the Company believes that the Proposal may be omitted because it relates to the Company's ordinary business operations.

The Proposal Relates to Pulte's Ordinary Business OperationsRule 14a-8(i)(7).

Pursuant to Rule 14a-8(i)(7), a shareholder proposal may be omitted from a company's proxy materials if the proposal "deals with a matter relating to the company's ordinary business operations." In Exchange Act Release No. 34-40018 (available May 21, 1998) (the "1998 Release"), the Commission stated that the ordinary business exclusion under Rule 14a-8(i)(7) rests on two central considerations: The first is that "certain tasks are so fundamental to management's ability to run a company on a day-to-day basis that they could not, as a practical matter, be subject to direct shareholder oversight." The second consideration relates to the degree to which the proposal seeks to "micro-manage" the company by probing too deeply into matters of a complex nature upon which shareholders, as a group, would not be in a position to make an informed judgment. Furthermore, in a 1983 release, the Staff stated that merely requesting that the registrant prepare a special report will not remove the proposal from the ordinary business grounds for exclusion. See Exchange Act Release No. 34-20091 (available Aug. 16, 1983). The Proposal at issue affects Pulte's ordinary business operations and seeks to "micro-manage" Pulte's essential business functions.

While proposals relating to ordinary business operations generally are excludable under 14a-8(i)(7), the Commission has made an exception to this general rule for proposals that might touch on ordinary business operations, but truly focus on significant issues of social policy. In the 1998 Release, the Commission noted that such proposals focusing on "sufficiently significant social policy issues ... would not be considered to be excludable, because the proposals would transcend the day-to-day business matters...."

While the Proposal has been cast in language suggesting a focus primarily on significant social policy issues, the Company believes the Proposal is instead, at its core, focused on the ordinary business matters of internal assessments of costs and potential revenues or losses related to Pulte's choice of products, raw materials and technologies. Although the Proposal requests that Pulte's Board of Directors provide a "climate change report" on the "feasibility of our company developing policies that will minimize its impacts upon climate change" (a seemingly social-policy focused request), the "feasibility of developing policies" for minimizing the impacts upon climate change is in fact a report on the feasibility of developing policies with respect to the selection and availability of particular products, raw materials and building technologies in view of local building codes, zoning requirements and other requirements of local municipalities, as well as current market conditions, customer preferences and competitive factors.

There is little question that the Proponents believe it is "feasible" for companies serving the residential sector to minimize their respective impacts upon climate change by adopting policies requiring the use of available technologies. In fact, this is presupposed by the Proponents, as evidenced by the inclusion of studies such as the McKinsey studies cited in the Proposal's supporting statement. The Proposal cites, for example: "The adoption of available technologies (including high-efficiency building shells, compact fluorescent lighting, and high-efficiency water heating) would cut ... end-use demand for energy by 32 QBTUs in 2020, equivalent to 5 percent of global end-user demand in that year." This, however, cannot be the type of feasibility analysis that is sought by the Proposal. Instead, any such feasibility analysis must focus not only on the impact of the use of available technologies on climate change, but, of necessity, on local building codes, zoning requirements and other requirements of local municipalities, as well as current market conditions, customer preferences, competitive factors and a cost-benefit evaluation with respect to the selection of the Company's product offerings, choice and availability of raw materials and building technologies. These are matters that clearly are within Pulte's ordinary business operations and are fundamental to management's ability to run the Company on a day-to-day basis. Thus, the proposal seeks the direct involvement of shareholders in management's judgments with respect to the Company's ordinary business operations.

That the Proposal's focus is, at its core, on economic matters is further acknowledged by a statement in the transmittal letter from The Nathan Cummings Foundation, which states in relevant part, "the Foundation believes that the way in which a company approaches major public policy issues has important implications for long-term shareholder value. It is with these considerations in mind that we submit this resolution...."

Judgments concerning the selection of products to be sold and raw materials to be used are inherently based on complex business considerations that are outside the knowledge and expertise of shareholders and fall within Pulte's ordinary business operations. The Staff has concurred with this view in numerous no-action requests. See, e.g., Walgreen Co. (Oct. 13, 2006) (permitting exclusion of a proposal requesting a report on the use of carcinogens and harmful chemicals in the company's private label cosmetics and personal care products lines and describing options for using safer alternatives); Wal-Mart Stores, Inc. (Mar. 24, 2006) (permitting exclusion of a proposal requesting a report evaluating the company's policies and procedures for minimizing customers' exposure to toxic substances in products); Seaboard Corporation (Mar. 3, 2003) (permitting exclusion of proposal requesting a report on use of antibiotics by company's hog suppliers); Kmart Corporation (Feb. 23, 1993) (permitting exclusion of a proposal that a company subsidiary stop sales of violent and/or sexually explicit literature and media); and The Kroger Co. (Mar. 23, 1992) (permitting exclusion of a proposal relating to products and product lines retailed by the company including the choice of processes and supplies used in the preparation of its products).

For Pulte specifically, the evaluation and selection of product offerings and raw materials involves complex analysis and decisionmaking with respect to a wide array of considerations relating to, among others, highly technical mechanical and structural issues associated with the use of new materials and technologies, choice of suppliers, cost and pricing considerations, evaluation of customer demand for specific products, evaluation of current market conditions and other competitive factors, all of which are business issues of a complex nature upon which shareholders, as a group, would not be in a position to make an informed judgment, and which should not be subject to "micro-management" by the Company's shareholders.

On a number of occasions the Staff also has granted relief under 14a-8(i)(7) where a shareholder proposal related to a company's choice of technologies, including International Business Machines Corporation (Jan. 6, 2005) (permitting exclusion of a proposal requesting the company to employ specific technology in its software); WPS Resources Corporation (Feb. 16, 2001) (permitting exclusion of a proposal requesting that a utility company develop new co-generation facilities and other technologies and improve energy efficiency); and Union Pacific Corporation (Dec. 16, 1996) (granting relief under Rule 14a-8(i)(7) to exclude a proposal requesting a report on the development and adaptation of a new railroad safety technology). The Proponents' request for a report with a specific focus on reducing greenhouse gas emissions from the Company's products and operations clearly deals with issues and considerations that directly and indirectly involve Pulte's choice of products, building technologies and raw materials, evaluation of costs and revenues or losses associated with the implementation of such products, technologies and materials, and other ordinary business operations. The ability to make these types of decisions has been recognized by the Staff on a number of occasions as being fundamental to management's ability to control the operations of the Company, and, as such, is not appropriately transferred to the Company's shareholders. Therefore, Pulte believes that the Proposal may be omitted from its 2008 Proxy in accordance with Rule 14a-8(i)(7).

Staff's Response

Pursuant to SLB 14C, in order to facilitate transmission of the Staff's response to our request during the highest volume period of the shareholder proposal season, our facsimile number is (312) 853-7036 and the Proponents' facsimile numbers are set forth below. Further, in appreciation of the Staff's work during the height of the proxy season, we have included photocopies of all no-action letters cited in this no action request as Appendix B.

Based on the foregoing, the Company respectfully requests the Staff's concurrence that the Proposal may be omitted and that it will not recommend enforcement action if the Proposal is excluded from the 2008 Proxy.

If you have any questions or need any additional information, please contact the undersigned. We appreciate your attention to this request.

Very truly yours,

/s/

Michael S. Sigal

Enclosures

cc: The Nathan Cummings Foundation 475 Tenth Avenue 14\th/ Floor New York, New York 10018 Attn: Laura Shaffer Fax: (212) 787-7377

Domini Social Investments 536 Broadway, 7\th/ Floor New York, New York 10012-3915 Attn: Karen Shapiro Fax: (212) 217-1101

cc: Providence Trust 515 SW 24\th/ Street San Antonio, Texas 78207-4619 Attn: Sr. Madonna Sangalli, CDP Fax: (210) 431-9965

General Board of Pension and Health Benefits of the United Methodist Church 1201 Davis Street Evanston, Illinois 60201 Attn: Laura Shaffer Fax: (847) 475-5061

SEIU Master Trust 11 Dupont Circle, N.W. Suite 900 Washington, D.C. 20036-1202 Attn: Stephen Albrecht Fax: (202) 842-0046

Mr. Steven M. Cook Vice President, General Counsel and Secretary Pulte Homes, Inc. 100 Bloomfield Hills Parkway Suite 300 Bloomfield Hills, Michigan 48304

[INQUIRY LETTER]

January 28, 2008

U.S. Securities and Exchange Commission
Division of Corporate Finance
Office of Chief Counsel
100 F Street, N.E.
Washington, D.C. 20549

Ladies and Gentlemen:

On behalf of our client, Pulte Homes, Inc. ("Pulte" or the "Company"), we are submitting this letter in response to the January 14, 2008 letter (the "Proponent Letter") submitted by The Nathan Cummings Foundation ("Nathan Cummings"). A copy of the Proponent Letter is attached hereto as Appendix A.

On December 28, 2007, we submitted a letter (the "Request Letter") in which we requested that the staff of the Division of Corporation Finance (the "Staff") take no enforcement action if, in reliance upon Rule 14a-8(i)(7), Pulte omits from the proxy materials it intends to distribute in connection with its 2008 Annual Meeting of Shareholders (the "2008 Proxy Materials") a shareholder proposal and statement in support thereof (the "Proposal") received from Nathan Cummings, as lead filer, Domini Social Investments, as co-filer, Providence Trust, as co-filer, the General Board of Pension and Health Benefits of the United Methodist Church, as co-filer, and SEIU Master Trust, as co-filer (collectively, the "Proponents"). The Proponent Letter was the Proponents' response to the Request Letter.

Pulte is of the view that Nathan Cummings' arguments, as set forth in the Proponent Letter, mischaracterize the Company's arguments in the Request Letter and oversimplify the nature of the Proposal. Pulte therefore continues to believe that it may exclude the Proposal from the 2008 Proxy Materials in reliance upon Rule 14a-8(i)(7).

In the Proponent Letter, Nathan Cummings asserts that the Proposal "contains no language suggesting a cost/benefit analysis...." Pulte disagrees with this assertion and believes that the Proposal would require a cost/benefit analysis. For example, Nathan Cummings states in the Proponent Letter that the Proposal's request could be satisfied by Pulte "describing available technologies" and determining "how likely each one would be to garner acceptance from Pulte's homebuyers." The likelihood that technologies would not be accepted by Pulte's homebuyers is, by its very nature, a cost/benefit analysis and risk assessment. In addition, the Proponent Letter cites the definition of "feasibility" in detail, including stating that something is "feasible" when, among other things, it is "capable of being used or dealt with successfully." Determining whether something is "capable of being used or dealt with successfully" inherently involves a cost/benefit analysis. Any such determination requires consideration not only of whether the proposed change is physically capable of being carried out, but also consideration of the associated costs relative to the anticipated benefits. As stated in the Request Letter, determinations of this nature are clearly within Pulte's ordinary business operations and are precisely the kind of tasks that are fundamental to management's ability to run the Company.

Moreover, Pulte disagrees with the assertion contained in the Proponent Letter that "the Proposal does not attempt to micromanage the Company's choice of products or technologies...." The Proposal requests that Pulte investigate the feasibility of developing policies that will minimize the impact upon climate change from the Company's products and operations. As a homebuilder, Pulte does not operate manufacturing or similar facilities that directly impact the environment (as is the case for companies in industries like those of Kimberly-Clark or 3M). Instead, the most significant manner in which Pulte may minimize its impact upon climate change is by producing homes that are more energy efficient. This out of necessity involves Pulte's choice of products, building materials and building technologies. As stated in the Request Letter, analysis of this nature involves consideration of a complex array of factors, including highly technical mechanical and structural issues associated with the use of new materials and technologies in view of local building codes, zoning requirements and other requirements of local municipalities, as well as choice of suppliers, cost and pricing considerations, evaluation of customer demand for specific products, evaluation of current market conditions and other competitive factors upon which shareholders, as a group, would not be in a position to make an informed judgment.

In addition, in response to Pulte's stated belief that the Proposal involves a cost/benefit analysis, Nathan Cummings suggests in the Proponent Letter that Pulte might implement the Proposal by providing one of a variety of reports, such as "outlin[ing] the geographical distribution of its homebuilding operations and discuss[ing] how it could adapt its practices in various regions to reduce greenhouse gas emissions." Pulte believes that the Proposal's request for a report discussing how Pulte "could adapt its practices" is deceptively simple. Any discussion of how Pulte might alter its building techniques or adopt new building materials is not so simple as merely determining whether alternate building materials could be used; rather, such an analysis is inherently complex and involves considerations of a highly technical nature, as explained in the Request Letter. Complex analyses of this nature are part of Pulte's ordinary business operations and as such, are excludable pursuant to Rule 14a-8(i)(7).

Pulte also believes that Walgreen Co. (Oct. 13, 2006), which was issued after the release of the CVS Corporation (Mar. 3, 2006) letter that Nathan Cummings cites in the Proponent Letter, is informative. In Walgreen Co., the shareholder proposal, which was similar to the shareholder proposal in CVS Corporation, requested a report that Walgreen Co. argued would have required it to engage a staff of scientists and various other experts to produce a specialized and complex scientific report, similar to what the Proposal requests of Pulte. The Staff allowed Walgreen Co. to exclude the shareholder proposal pursuant to Rule 14a-8(i)(7).

For the reasons discussed above and in the Request Letter, Pulte respectfully reiterates its request for confirmation that the Staff will not recommend enforcement action if Pulte omits the Proposal from the Company's 2008 Proxy Materials.

If you have any questions or need additional information, please contact the undersigned. We appreciate your attention to this request.

Very truly yours,

/s/

Michael S. Sigal

Enclosures

cc: The Nathan Cummings Foundation 475 Tenth Avenue 14th Floor New York, New York 10018 Attn: Laura J. Shaffer Fax: (212) 787-7377

Domini Social Investments 536 Broadway 7th Floor New York, New York 10012-3915 Attn: Karen Shapiro Fax: (212) 217-1101

Providence Trust 515 SW 24th Street San Antonio, Texas 78207-4619 Attn: Sr. Madonna Sangalli, CDP Fax: (210) 431-9965

cc: General Board of Pension and Health Benefits of the United Methodist Church 1201 Davis Street Evanston, Illinois 60201-4118 Attn: Vidette Bullock Mixon Fax: (847) 475-5061

SEIU Master Trust 11 Dupont Circle, N.W. Suite 900 Washington, D.C. 20036-1202 Attn: Stephen Abrecht Fax: (202) 842-0046

Mr. Steven M. Cook Vice President, General Counsel and Secretary Pulte Homes, Inc. 100 Bloomfield Hills Parkway Suite 300 Bloomfield Hills, Michigan 48304

[INQUIRY LETTER]

January 14, 2008

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Attention: Chief Counsel, Division of Corporation Finance

Re: Request by Pulte Homes, Inc. to omit shareholder proposal submitted by The Nathan Cummings Foundation and several co-sponsors

Dear Sir/Madam,

Pursuant to Rule 14a-8 under the Securities Exchange Act of 1934, The Nathan Cummings Foundation (the "Foundation") and several co-sponsors (together, the "Proponents") submitted a shareholder proposal (the "Proposal") to Pulte Homes, Inc. ("Pulte" or the "Company"). The Proposal asks Pulte's board to report to shareholders on the feasibility of developing policies that will minimize the Company's impacts on climate change, with a focus on reducing greenhouse gas emissions from Pulte's products and operations.

By letter dated December 28, 2007, Pulte stated that it intends to omit the Proposal from the proxy materials to be sent to shareholders in connection with the 2008 annual meeting of shareholders and asked for assurance that the Staff would not recommend enforcement action if it did so. Pulte argues that it is entitled to exclude the Proposal in reliance on Rule 14a-8(i)(7), which allows a company to exclude a proposal that "deals with a matter related to the company's ordinary business operations." Because Pulte has not met its burden of proving that the Proposal is excludable, its request for relief should be denied.

At the outset, Pulte concedes that the Proposal's language "suggest[s] a focus primarily on significant social policy issues" mitigating climate change. Nonetheless, Pulte claims that the Proposal is excludable because it focuses on "internal assessments of costs and potential revenues or losses related to Pulte's choice of products, raw materials and technologies." In Pulte's view, the Proposal is excludable because it asks for a cost/benefit analysis and because it deals with the Company's choice of products and technologies. Neither of these characterizations is accurate.

In Staff Legal Bulletin 14C ("SLB 14C"), the Staff clarified the circumstances under which a company can rely on the ordinary business exclusion to omit a proposal relating to the environment or public health on the grounds that it asks for an evaluation of risks and benefits. SLB 14C states:

In determining whether the focus of these proposals is a significant social policy issue, we consider both the proposal and the supporting statement as a whole. To the extent that a proposal and supporting statement focus on the company engaging in an internal assessment of the risks or liabilities that the company faces as a result of its operations that may adversely affect the environment or the public's health, we concur with the company's view that there is a basis for it to exclude the proposal under rule 14a-8(i)(7) as relating to an evaluation of risk. To the extent that a proposal and supporting statement focus on the company minimizing or eliminating operations that may adversely affect the environment or the public's health, we do not concur with the company's view that there is a basis for it to exclude the proposal under rule 14a-8(i)(7).

The Proposal does not ask Pulte to "engag[e] in an internal assessment of the risks or liabilities that the company faces as a result of its operations" that contribute to climate change. The Proposal contains no language suggesting a cost/benefit analysis or asking Pulte to quantify the potential liabilities or risks Pulte faces as a result of its operations' environmental impacts.

That the Proposal asks Pulte to report on the "feasibility" of adopting policies to minimize the Company's impact on climate change does not compel a conclusion that the Proposal seeks a cost/benefit analysis, as Pulte urges. Something is feasible when it is "capable of being done or carried out," "capable of being used or dealt with successfully" or "reasonably likely." 1 In CVS Corp., the Staff rejected an argument similar to the one Pulte makes here, refusing to allow exclusion of a proposal asking the company to evaluate the feasibility of reformulating its private label products to eliminate certain chemicals and encouraging or requiring manufacturers or distributors of other cosmetics products sold in CVS to do the same. CVS had argued that the proposal sought an "evaluation of risk" and was thus excludable under the reasoning set forth in SLB 14C.

The Proposal focuses on Pulte reducing or eliminating harm to the environment and reporting to shareholders on how this might be possible. The bulk of the supporting statement is devoted to a discussion of greenhouse gas emissions and the contributions of residential buildings to climate change.

Implementation of the Proposal could assume many forms, none of which would require cost/benefit analysis or risk assessment. For example, Pulte might respond by describing available technologies or measures and setting forth its opinion of how likely each one would be to garner acceptance from Pulte's homebuyers. Pulte might outline the geographical distribution of its homebuilding operations and discuss how it could adapt its practices in various regions to reduce greenhouse gas emissions. None of these discussions would require cost/benefit analysis.

Moreover, the Proposal does not attempt to micromanage the Company's choice of products or technologies, as Pulte claims. Unlike some of the proposals in the determinations cited by Pulte, which asked the companies to stop selling certain products, the Proposal simply asks Pulte to report on possible avenues for reducing the Company's impact on climate change.

Similarly, the Proposal does not try to control Pulte's choice of technologies, which was the case in the proposals Pulte cites. On this point, Pulte also argues that the report requested in the Proposal would be too complex and difficult for shareholders to understand. However, the "wide array of considerations" Pulte cites, including choice of suppliers, cost and pricing considerations, customer demand, current market conditions and other competitive factors, are very similar to if not exactly the same as matters regularly discussed in corporate annual reports.

Further, some companies have already begun reporting on their efforts to mitigate climate change. For example, Kimberly-Clark's sustainability report, published on its web site, quantifies its greenhouse gas emissions, describes measures the company is taking to reduce them and discusses energy efficiency issues.2 3M provides similar information in its sustainability report.3 Institutional investors and the Investor Network on Climate Risk, an organization of investors with $4 trillion in assets under management,4 have been engaging in sophisticated and high-level dialogues with companies about their strategies for dealing with climate change.

All of these facts, coupled with the high level of support received by climate change shareholder proposals in 2007just under 20% on average and 39.5% at Allegheny Energy5demonstrate that shareholders are capable of understanding the climate change issue and measures companies are taking or considering taking to mitigate their contributions to climate change. Indeed, the Proponents would not have submitted the Proposal if they did not believe that they and many other shareholders would benefit from having the information in the requested report.

In sum, the Proposal falls comfortably within the class of proposals described in SLB 14C as not being excludable on ordinary business grounds. There is no dispute that the subject of reducing a company's contribution to global climate change implicates a significant social policy issue.6 The Proposal does not ask for a cost/benefit analysis or risk assessment, nor does it seek to micro-manage the Company's product selection or choice of technologies. Accordingly, Pulte should not be permitted to exclude the Proposal in reliance on the ordinary business exclusion.

If you have any questions or need anything further, please do not hesitate to call me at (212) 787-7300. The Foundation appreciates the opportunity to be of assistance in this matter.

Very truly yours,

/s/

Laura J. Shaffer
Director of Shareholder Activities

cc: Michael S. Sigal Sidley Austin LLP Fax # 312-853-7036

-----FOOTNOTES-----

1 See Merriam-Webster definition at http://www.m-w.com/dictionary/feasibility.

2 See http://www.kimberly-clark.com/aboutus/Sustainability/sustainability_pg35.aspx and http://www.kimberly-clark.com/aboutus/Sustainability/sustainability_pg34.aspx.

3 See http://solutions.3m.com/wps/portal/3M/en_US/global/sustainability/management/climate-change-energy/.

4 See http://www.incr.com/NETCOMMUNITY/Page.aspx?pid=198&srcid=-2.

5 See Riskmetrics Group, "2007 Postseason Report," at 35-36 (Oct. 2007) (available at http://www.riskmetrics.com/pdf/2007PostSeasonReportFINAL.pdf).

6 See, e.g., Unocal Corporation (publicly available Feb. 23, 2004) (declining to allow exclusion of a proposal asking the company to report on "how the company is responding to rising regulatory, competitive, and public pressure to significantly reduce carbon dioxide and other greenhouse gas emissions"); Reliant Resources Inc. (publicly available Mar. 5, 2004) (same).

[INQUIRY LETTER]

November 26, 2007

Mr. Steven M. Cook
VP, General Counsel & Secretary
Pulte Homes, Inc.
100 Bloomfield Hills Parkway, Suite 300
Bloomfield Hills, Michigan 48304

Dear Mr. Cook:

The Nathan Cummings Foundation is an endowed institution with approximately $570 million of investments. As a private foundation, the Nathan Cummings Foundation is committed to the creation of a socially and economically just society and seeks to facilitate sustainable business practices by supporting the accountability of corporations for their actions. As an institutional investor, the Foundation believes that the way in which a company approaches major public policy issues has important implications for long-term shareholder value.

It is with these considerations in mind that we submit this resolution for inclusion in the Pulte Homes, Inc. proxy statement under Rule 14a-8 of the general rules and regulations of the Securities Exchange Act of 1934. We would appreciate an indication in the proxy statement that the Nathan Cummings Foundation is the primary proponent of this resolution. At least one representative of the filers will attend the stockholders' meeting to move the resolution as required by the rules of the Securities and Exchange Commission.

The Nathan Cummings Foundation is the beneficial owner of over $2,000 worth of shares of Pulte Homes, Inc. stock. Verification of this ownership, provided by Northern Trust, our custodian bank, is included with this letter. We have continuously held over $2,000 worth of the stock for more than one year and will continue to hold these shares through the shareholder meeting.

If you have any questions or concerns about this resolution or would like to speak with us about your efforts to address climate change, please contact Laura Shaffer at (212) 787-7300. Thank you for your time.

Sincerely,

/s/

Lance E. Lindblom
President and CEO

/s/

Laura J. Shaffer
Director of Shareholder Activities

cc: Interfaith Center on Corporate Responsibility Members and Associates

[APPENDIX]

The Intergovernmental Panel on Climate Change (IPCC) recently concluded that warming of the climate system is unequivocal and that human activity is the main cause. Debate surrounding climate change now focuses not on whether a problem exists but rather on the best means for abatement and adaptation.

The rise in average global temperatures resulting from climate change is expected to have significant adverse impacts. According to Business Week, many scientists agree that the warmer temperatures resulting from climate change are causing more powerful storms and perhaps intensifying extreme weather events including droughts and wild fires. Thermal expansion and melting ice sheets are expected to lead to rising sea levels, with significant implications for coastal communities. Rising temperatures will also impact fresh water supplies. California's Department of Water Resources, for instance, has stated that, "Adapting California's water management systems to climate change presents one of the most significant challenges for the 21\st/ century."

Climate change also has important economic implications. The Stern Review, often cited as the most comprehensive overview of the economics of climate change, estimated that the cumulative economic impacts of climate change could be equivalent to a loss of up to 20% of average world-wide consumption if action is not taken quickly. A more general pronouncement in the IPCC's report, Climate Change 2007: Impacts, Adaptation and Vulnerability, observed that "Taken as a whole, the range of published evidence indicates that the net damage costs of climate change are likely to be signif cant and to increase over time."

According to the Washington Post, "Buildings are the largest source of the greenhouse-gas emissions that are causing global warming, and in the United States, half of building-related emissions are from houses." The EPA estimates that the residential end-use sector accounted for 21% of CO2 emissions from fossil fuel combustion in 2005.

With residential end-use accounting for such a high proportion of GHG emissions stemming from fossil fuel combustion, a number of recent studies have focused on energy efficiency improvements in residential dwellings as a potential source of emission reductions. One recent study in The McKinsey Quarlerly found that nearly a quarter of cost-effective GHG abatement potential involves efficiency-enhancing measures geared at reducing demand in the buildings and transportation sectors. A second McKinsey study concluded that the residential sector represents the single-largest opportunity to raise energy productivity, noting that, "The adoption of available technologies (including high-efficiency building shells, compact fluorescent lighting, and high-efficiency water heating) would cut ... end-use demand for energy by 32 QBTUs in 2020, equivalent to 5 percent of global end-user demand in that year."

RESOLVED:

Shareholders request that by December 31, 2008 the Board of Directors provide a climate change report, prepared at reasonable cost and omitting proprietary information, on the feasibility of our company developing policies that will minimize its impacts upon climate change, with a focus on reducing greenhouse gas emissions from the company's products and operations.

[STAFF REPLY LETTER]

February 11, 2008

Response of the Office of Chief Counsel Division of Corporation Finance

Re: Pulte Homes, Inc. Incoming letter dated December 28, 2007

The proposal requests that the board provide a climate change report on the feasibility of Pulte Homes developing policies that will minimize its impacts upon climate change, with a focus on reducing greenhouse gas emissions from its products and operations.

We are unable to concur in your view that Pulte Homes may exclude the proposal under rule 14a-8(i)(7). Accordingly, we do not believe that Pulte Homes may omit the proposal from its proxy materials in reliance on rule 14a-8(i)(7).

Sincerely,

/s/

William A. Hines
Special Counsel