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r+ -• »� r• .r rMLA i rii 1 is t-msoc iates i u San Joaquin Co P.09 BUCKEYE RANCH ( 4-1-92 ) 9 sites were planted in vineyards and asparagus it possible their integrity has been compromised severely but probably not anymore than that of the lumped "TRACY LAKE SITE" . On what basis is Tracy Lake defined as a pluvial lake that would have provided an abundant resource base for Paleolndians. The lake size is so small and ephemeral it bears no relationship to the large well defined pluvial lakes found elsewhere in California. In addition the Sacramento/San Joaquin delta did not begin to form until within the last 4500 years thus the marsh lands currently to the west were dry land with associated river channels . It is likely that earlier peoples living or passing through the area would have travelled further west and that , as Moratto ( 1934 ) has stated. the older sites may be under the alluvial soils and delta pests . At the University of California. Davis campus buried soils radio carabon dated at just over 4. 000 vears ago . in the Highway 113 road cut , are below eight to ten feet of alluvium. It is clear therefore that the resource base and conditions at and around what are now the Tracy Lakes was quite different several thousand years ago. Based on Current information it appears that very little was going on in the Tracy Lakes locality until quite recently prehistorically. The location of a potentially older prehistoric site, based on soil chemistry. mightrepresent an earlier occupation sequence in the locality but thi,s remains to be defined. 3 ) . The suggestion in the Cultural Resources section of the E. I .R. that three of the cultural resources identified by the consulting archaeologists were relatively undisturbed is clearly in need of reevaluation. The OTRACY LAKE" site defined by the consulting • archaeologists as a single site has been virtually destroyed in some aspects . Portions of midden deposits have been .used for borrow and for levee construction . One midden remnant on the south shore of South Tracy Lake probably exists only because it has a telephone pole in it . The rest of the deposit had been bulldozed away. Extensive vandalism apparently occurred 1 probably at other locations as well . Within the tree line at Brovelli Woods there is extensive evidence of land disturbance in the past and in some places there are large deep elongated pits and trenches which may represent periods in the past when the Mokelumne River overflowed in the woods and washed out areas of unconsolidated alluvial deposits. 4) . In chapter 3 the suggested mitigation measures are most often inappropriate since the consulting archaeologists have not defined were the cultural resources are in relationship to the proposed developments within the project . To make broad generalizing site boundaries and then suggest that everything within those areas should be eliminated is su;gestin a precedent that would preclude any type of development within t9e vicinity of any riparian habitat in San Joaquin County or elsewhere. If the specific boundaries of each midden deposit is defined and isolated features and artifacts taken into consideration it is possible that the archaeological resources can be protected without eliminating completely any develowent on the shores of Tracy Lake . On Page 3-16 it is implied t9at the only way to ovoid significant impact to the archaeological sites is to basically leave the area undisturbed Vith no development on or in the vicinity of the four locations identified by the consultins� archaeologists. The sites have already been heavily impacted by