December 17, 2018

Daemon P. Repp
Director of Finance
Pope Resources , A Delaware Limited Partnership
11950 Seventh Ave NE
Suite 200
Poulsbo, WA 98370

       Re: Pope Resources , A Delaware Limited Partnership
           Form 10-K for the Year Ended December 31, 2017
           Filed March 2, 2018
           File No. 001-09035

Dear Mr. Repp:

       We have limited our review of your filing to the financial statements
and related
disclosures and 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 business days by providing
the requested
information or advise 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 Fiscal Year Ended December 31, 2017

Item 6. Selected Financial Data, page 26

1.    We note your presentation of various measures (e.g., revenue, operating
income and
      harvest volume) on a look-through basis. On page 4, you indicate this
represents the
      combination of the Partnership's tree farms and its 20%, 5%, and 15%
ownership interest
      in Fund II, Fund II, and Fund IV, respectively. On page 27, you indicate
the depiction
      reflects an adjustment to the GAAP financial items. The measures
presented on a look-
      through basis appear to represent non-GAAP measures as defined by and
subject to the
      provisions of Regulation G and Item 10(e) of Regulation S-K.

      Further, we note that the Funds are considered to be variable interest
entities for which the
      Partnership is the primary beneficiary. Considering that the Funds are
consolidated into
      the Partnership's financial statements as the Partnership has the
authority to direct the
 Daemon P. Repp
Pope Resources , A Delaware Limited Partnership
December 17, 2018
Page 2
         activities that most significantly impact the economic performance, as
well as the right to
         receive benefits and obligation to absorb losses that could
potentially be significant to the
         Partnership, presenting non-GAAP measures on an other than
consolidated basis could
         violate Rule 100(b) of Regulation G. Please refer to Question 100.04
of the SEC's
         Compliance and Disclosure Interpretations for Non-GAAP Financial
Measures and tell us
         how you have considered this guidance.

         This comment is also applicable to the extent these measures are
presented in your
         earnings releases filed on Form 8-K.
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Heather Clark at 202-551-3624 or Melissa Raminpour at
202-551-3379
with any questions.



FirstName LastNameDaemon P. Repp                     Sincerely,
Comapany NamePope Resources , A Delaware Limited Partnership
                                                     Division of Corporation
Finance
December 17, 2018 Page 2                             Office of Transportation
and Leisure
FirstName LastName