Friends of Gualala River Protecting the Gualala River watershed and the species living within it
The 289-acre Lucas Point timber harvest plan (THP 1-25-00099-SON) is a revised version of the Bootleg THP (1-20-00293-SON), located in the Middle South Fork of the Gualala River watershed, south of Stewarts Point and adjacent to Tin Barn Road.
The Bootleg THP was successfully challenged by Friends of the South Fork Gualala. Sonoma County Superior Court found that the Bootleg plan lacked sufficient analysis of the environmental impacts and contained only conclusory assertions lacking facts and analysis, specifically as to sedimentation, biological resources, and cultural resources. In addition, the plan failed to adequately analyze cumulative impacts, and failed to consider a reasonable range of project alternatives.
The Lucas Point THP was approved by Cal Fire on October 24, 2025.
Note: CalFire’s standard procedure is to print out the plan documents, scan them, and post the images to their publicly accessible database, CalTREES. As a result, it is impossible to search for text in the documents, because there are no words in the documents posted, only images of words. In order to make the documents more useful, we have used optical character recognition (OCR) on the documents posted below, so that you can search them.
Lucas Point Timber Harvest Plan documents
Lucas Point THP Section 1 – Legal description [2 MB, 8 pages]
Cover pages, signatures.
Lucas Point THP Section 2 – Operations [10 MB, 86 pages]
Silviculture, Yarding, Erosion Hazard Rating, Winter operations, Roads & landings, Watercourse & lake protections, Alternative Watercourse & lake protections (in lieu of standard rules), Wildlife observances & enforceable provisions, Maps
Lucas Point THP Section 3 – Supporting materials [2 MB, 37 pages]
General Site Description, Analysis of Alternatives, Discussion and Justification of Section I & II items: Silvicultural Methods, Ground-based equipment on steep slopes & unstable areas, Roads, Landings and Skid Trails, Additional in-lieu and/or alternative watercourse and lake protection practices, Listed Species, Including Habitat.
Lucas Point THP Section 4 – Cumulative Impacts [5 MB, 129 pages]
Past, present and future projects, assessment of cumulative watershed effects, soil productivity, biological resources, recreational, visual, traffic, greenhouse gas impacts, wildfire risks
Lucas Point THP Section 5 – Attachments [22 MB, 166 pages]
Including soil erosion hazards, Focused Engineering Geologic Review, Erosion Control Plan, botanical surveys, Northern Spotted Owl & Marbled Murrelet information.
Lucas Point THP Section 6 – Archeological information [1 MB, 1 page]
(confidential)
Public Comments on the Lucas Point THP
Comments by Friends of the South Fork Gualala – Please extend comment period
Apparently CalTrees has been taken down for 5 days, 09/04/25 – 09/09/25, precisely during the middle of our short public comment period! This represents a significant portion of the public comment period, which ends 09/15/25. We respectfully request that end of public comment dates be extended for one day for each day that CalTrees is out of service, as this is disrupting our ability to view and evaluate the THP.
Comments by Friends of the South Fork Gualala – Re-submittal of the Bootleg THP
“This THP is essentially a re-submittal of THP 1-20-00203-SON “Bootleg,” which was annulled and set aside by the Sonoma County Superior Court for multiple failures to comply with the California Environmental Quality Act (CEQA). The Lucas Point THP proposes the same harvest area and silviculture plan as the Bootleg THP, and therefore the public’s prior comments and significant environmental concerns remain directly applicable.”
Comments by Friends of the South Fork Gualala – Alternatives Analysis
“On behalf of Friends of the South Fork Gualala (FoSFG), please consider and respond to the CEQA violations in the alternative analysis section of Falk Forestry’s proposed Timber Harvest Plan 1-25-00099-SON “Lucas Point”.”
Comments by Friends of the South Fork Gualala – Cumulative Impact Assessment
“Friends of the South Fork Gualala submits these comments on the cumulative impact assessment in Section 4 of THP 1-25-00099-SON (the “Lucas Point THP”).”
Comments by Friends of the South Fork Gualala – Misleading, False & Irrelevant
“Given the overwhelming and irrefutable scientific and factual evidence provided throughout this public comment, the multiple demonstrations of misleading facts and false statements, it is clear that THP 1-25-00099-SON “Lucas Point”, is woefully misguided, has completely failed to provide an accurate cumulative impacts analysis as required by law, includes significant conflicts of interest, and should be denied.”
Comments by Friends of the South Fork Gualala – Northern Spotted Owls
“The Lucas Point THP does not assess the cumulative impacts on Northern spotted owls (‘NSO’) from logging in this and past and reasonably foreseeable logging projects in the Biological Assessment Area (BAA).” Attachments:
FWS: NSO Listing Decision
FWS: NSO Species Status Report
FWS: NSO Warranted but Precluded
PNW: NSO Habitat and Populations: Status and Threats
FWS: NSO Critical Habitat Listing
Comments by Peter Schmidt, PhD. – Archeological Survey Methods
“I have previously brought to your attention that it is impossible to evaluate the adequacy of an archeological survey if no detailed information is provided about the methods used. There is nothing in the law that prevents methods from being discussed.”
Comments by Dave Hope, RPF, CPESC (ret.) – Sedimentation, Erosion, & Salmonids
“The Lucas Point THP proposes timber harvesting in an area that the THP repeatedly acknowledges is unstable. In my professional opinion, if timber harvesting occurs as currently proposed, it is likely to cause increased erosion and sedimentation in the South Fork Gualala River, and in downstream in the Gualala River itself. In degraded watercourses such as the South Fork Gualala, any increase in sedimentation adversely affects salmonids.”
Comments by Chad Hanson, PhD. – Fatal Deficiencies in the Wildfire Analysis
“I am the co-editor and co-author of the 2015 forest/fire ecology textbook, “The Ecological Importance of Mixed-Severity Fires: Nature’s Phoenix”, the 2021 book, “Smokescreen: Debunking Wildfire Myths to Save Our Forests and Our Climate”, and the 2024 book, “Mixed-Severity Fires: Nature’s Phoenix”.”
Official Response to Public Comments
The Department recognizes its responsibility under the Forest Practice Act (FPA) and CEQA to determine whether environmental impacts will be significant and adverse. In the case of the management regime which is part of the THP, significant adverse impacts associated with the proposed application are not anticipated. . .
All documents regarding this logging plan are available in the new CalTREES system.
Unfortunately, CalTREES is not easy to use, so FoGR has compiled some
basic instructions for use of CalTREES to help you navigate the system.
To download additional documents for this logging plan,
if you want to follow the back & forth as agencies ask questions and the RPF replies,
visit the Lucas Point THP page on the CalTREES website.
The public comment period has ended. Below are instructions on how to submit comments during the public comment period.
To submit your comments on a logging plan, email your comments to: santarosapubliccomment@fire.ca.gov
or send your comments via U.S. Mail to:
Forest Practice
California Department of Forestry and Fire Protection
135 Ridgway Ave.
Santa Rosa, CA 95401
In the subject line of your email message, or at the top of your letter,
be sure to reference the THP number and name, for example:
THP 1-25-00099-SON “Lucas Point”