Report of Independent Registered Public
Accounting Firm

To the Board of Trustees and Shareowners of
Pioneer Real Estate Shares
In planning and performing our audit of the
financial statements of Pioneer Real Estate
Shares (the Company) as of and for the year
ended December 31, 2008, in accordance with
the standards of the Public Company
Accounting Oversight Board (United States), we
considered the Company's internal control over
financial reporting, including controls over
safeguarding securities, as a basis for
designing our auditing procedures for the
purpose of expressing our opinion on the
financial statements and to comply with the
requirements of Form N-SAR, but not for the
purpose of expressing an opinion on the
effectiveness of the Company's  internal control
over financial reporting. Accordingly, we
express no such opinion.
The management of the Company is
responsible for establishing and maintaining
effective internal control over financial reporting.
In fulfilling this responsibility, estimates and
judgments by management are required to
assess the expected benefits and related costs
of controls. A company's internal control over
financial reporting is a process designed to
provide reasonable assurance regarding the
reliability of financial reporting and the
preparation of financial statements for external
purposes in accordance with generally
accepted accounting principles. A company's
internal control over financial reporting includes
those policies and procedures that (1) pertain to
the maintenance of records that, in reasonable
detail, accurately and fairly reflect the
transactions and dispositions of the assets of
the company; (2) provide reasonable assurance
that transactions are recorded as necessary to
permit preparation of financial statements in
accordance with generally accepted accounting
principles, and that receipts and expenditures of
the company are being made only in
accordance with authorizations of management
and directors of the company; and (3) provide
reasonable assurance regarding prevention or
timely detection of unauthorized acquisition,
use or disposition of a company's assets that
could have a material effect on the financial
statements.
Because of its inherent limitations, internal
control over financial reporting may not prevent
or detect misstatements. Also, projections of
any evaluation of effectiveness to future periods
are subject to the risk that controls may become
inadequate because of changes in conditions,
or that the degree of compliance with the
policies or procedures may deteriorate.
A deficiency in internal control over financial
reporting exists when the design or operation of
a control does not allow management or
employees, in the normal course of performing
their assigned functions, to prevent or detect
misstatements on a timely basis. A material
weakness is a deficiency, or a combination of
deficiencies, in internal control over financial
reporting, such that there is a reasonable
possibility that a material misstatement of the
company's annual or interim financial
statements will not be prevented or detected on
a timely basis.
Our consideration of the Company's internal
control over financial reporting was for the
limited purpose described in the first paragraph
and would not necessarily disclose all
deficiencies in internal control that might be
material weaknesses under standards
established by the Public Company Accounting
Oversight Board (United States).  However, we
noted no deficiencies in the Company's internal
control over financial reporting and its
operation, including controls over safeguarding
securities, that we consider to be a material
weakness as defined above as of December
31, 2008.
This report is intended solely for the information
and use of management and the Board of
Trustees of Pioneer Real Estate Shares and the
Securities and Exchange Commission and is
not intended to be and should not be used by
anyone other than these specified parties.


Ernst & Young LLP

Boston, Massachusetts
February 18, 2009