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In their report, Ananian and Rice (1991), refer to the identified prehistoric sites as the Tracy Lakes Complex, and find this complex an "important archaeological resource" under all five CEQA criteria, and further suggest it may be eligible for the National Register of Historic Places, citing its integrity, uniqueness, and research value. 2.3.3 Public Reviews of Recent Investigation Public review of Ananian and Rice's Draft report (1991) elicited comments from Jerald Johnson of the Anthropology Department at CSUS (1992), Debbie Pilas-Treadway of the Native American Heritage Commission (1992), Joan Villa of the Ione Band of Miwok: Mokelumne- Locolumne Tribe (1992), and Alvin Walloupe of the Amador Tribal Council (1992). Johnson, acting as a consultant for the Robertson Homes, made three visits to the project area in the spring of 1992, evaluated the cultural resources study, and concluded the following: (1) the consulting archaeologists did not find all of the cultural resources; (2) they inadequately determined the characteristics of the known and newly recorded resources; and (3) the archaeological site records supplied to San Joaquin County were inadequate. Additional and detailed comments were provided (see Appendix 1.1). Johnson recommended that all the cultural resources that might be impacted by the proposed subdivision be precisely located. He later provided the county with a suggested scope of work. Pilas-Treadway (1992), representing the Native American Heritage Commission, also expressed concern that not all resources had been identified. She suggested that a supplementary report be prepared by an archaeologist who would be found acceptable to the local Native American community (see Appendix 1.2). Villa (1992), representing the Mokelumne-Locolumne Tribe of the Ione Band of Miwok, informed the SJCCDD that the project vicinity is a very sacred area to the Tribe and that the members of the Tribe are direct blood descendants to the burials in that region. The SJCCDD was advised that the Tribe asserts its authority over its aboriginal territories which include, but are not limited to the Buckeye Ranch Project. The Tribe further requested a Memorandum of 11