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Ihi-lti-177G lr:lr rra-IM Mills Hssociates TO San Joaquin Co P.08 <br /> BUCKEYE RANCH <br /> reporting of the site deposit as the same as the surrounding <br /> soils when in fact middens are quite distinctive and do not <br /> have the same chemistry or texture as the surrounding soils <br /> as demonstrated above. In addition there are numerous other <br /> errors that need to be corrected. <br /> 2) . The discussion on the background of the prehistory of the <br /> Tracy Lake area is totally inadequate and misleading. It is <br /> stated that the Tracy Lake sites played a significant role in the <br /> formulation of the Central California Taxonomic System of <br /> cultural classification. Thisis simply not true . The <br /> Windmiller Culture ( Early Horizon ) was defined on the bases of <br /> sites south of the Mokelumne River and one site on the Cosumnes <br /> River since little if anHmaterial of this age has been found at <br /> Tracv Lake . The Middle orizon Was defined almost entirely on <br /> the basis of archaeological sites in Sacramento County and no <br /> evidence of any significant amount of material of this antiquity <br /> was found in any of the sites at which excavations were conducted <br /> Within the project boundaries . The Late Horizon was also defined <br /> for the most part on sites within Sacramento County and none of <br /> the site numbers cited within the proposed Buckeye Ranch <br /> Subdivision were ever mentioned in any of the publications which <br /> defined the Central California Taxonomic System. <br /> There is constant reference to one projectile point base and one <br /> crescent that are supposed to represent the possibility that the <br /> Tracy Lake locality may have been used as early as 13 . 000 years <br /> ago by PaleoIndians . Neither of these specimens were found in <br /> archeological deposits . The point base was on the surface and <br /> the crescent was in the Mokelumne River Channel . Heizer in a 1938 <br /> article indicated that many projectile points found within the <br /> Early Horizon (Windmiller'Culture) have a similar form and basal <br /> grinding and thinning not inconsistent with the specimen from <br /> Tracy Lake. He indicates that it could just as easily date <br /> within the last 4500 years. It is possible that this point was <br /> picked up by much later inhabitants of the Tracy Lake locality <br /> from the older sites across the river and closer to Thornton.. <br /> Crescents in California generally date between 7. 500 to 9 , 000 <br /> Years ago , but a single specimen out of context does not really <br /> tell us much about its potential significance or antiquity. In <br /> actuality the excavations by Dawson in the 1920s and those by <br /> Mcgeein and Moyer in the 19705 clearly suggest that most of the <br /> prehistory that has been defined occurred within the last 500 to <br /> 1 , 000 years . <br /> The archaeological consultants also use all inclusive terminology <br /> when discussing cultural resources which is not appropriate. <br /> They indicate that the cultural resources at Tracy Lake are- the <br /> last relatively intact prehistoric sites in Sin Joaquin County. <br /> This is simply not true . San Joaquin County extends into the <br /> Sierra Nevada foothills and one of the largest collections of <br /> archaeological sites in California occurs within this re ion. <br /> Since much of this foothill country contains riparian habitat and <br /> most likely numerous archaeological sites which have yet to be <br /> recorded it is likely that a substantial number of sites still <br /> exist . In addition while contemplating a possible Ph.D . <br /> dissertation <br /> project from Camanche Reservoir to the Delta this <br /> reviewer visited some very large prehistoric sites on the south <br /> side of the Mokelumne River which were far larger tbAn anything <br /> viewed at Tracy Lake . Some of those sites had very deep deposits <br /> and som* of the assoeiatcd valley oak trees were over four feet <br /> in diameter. Since this was 28 years ago and since many of these <br />