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I'"T-14-177G 1x•17 rKu111 Mils Hssoclates lu 5an Joaquin Lo H. 11 BUCKEYE RANCH ( 4-1-92 ) 11 have also not determined the depth and probable mass of the excavatable deposits suggestions of test excavations are not appropriate. The draft report says that recordation. including mapping and photography, should follow (at minimum) the standard procedures of the Department of Parks and Recreation . It is unfortunate that the recording of the sites did not meet the professional standards of the State Historic Preservation Office . On Page 3-20 it says pollen and soil analyses representative of each site locality should be performed. dependent upon the material available . It is clear that the consulting archaeologists have put the cart before the horse . Appropriate chemical tests of the soils should have been performed to determine the limits of the excavatable deposits within the project so that they could be evaluated in regard to proposed developments . Since the consulting archaeologists have not identified what is still present , and what affect all of the past destructive activities have done to these deposits it is not appropriate to suggest collection of pollen samples at this time. On Page 3-20 it is noted that the "RIVER SITE" extends beyond the Droient . It is evident to this reviewer that are located outside of the Project bouncaries . and that only a levelled remnant of is present in the location of the I Since the bulk of the lumped together "RIVER SITE" is outsiae the proposed Buckeye Ranch Subdivision this would drastically alter any mitigation procedures that may be ultimately needed. It is difficult to understand how a suggestion can be made to excavate units in the "RIVER SITE" to a depth of approximately three meters when the 1929 report of Schenck and Dawson indicate that sterile was reached in _ at a depth of three feet (one meter ) and'- in four feet ( 1 . 22 meters ) . Even if burials extended into the sterile subsoil , as was the case with many that were excavated by Donald Mcgeein , the maximum depth does not begin to approach throe meters . One of the major faults of the work performed by the consulting archaeologists was the failure to use auguring to determine the actual dept-.-,s of the excavatable deposits . Based on the indicated location of the two sites on the south side of the Mokelumne River and the nature of the impact from the project it is probably not necessary to have a survey conducted to locate those resources . The rest of the suggestions on Page 3-21 are valid, though it might be difficult to find a third Party professional organization willing to monitor the sites within the project . Perhaps it should be the responsibility of work done by the consulting archaeologists affiliated with the project -in the future to identify such organizations. r 5 ) . In Chapter 4. 9 and Appendix F in the Draft E. I .R. there are also some misleading and wrong information. On Page 4 . 9-2 the consulting archaeologists have ctearly not demonstrated that only two sites exist . The nature of the fieldwork carried out was insufficient to demonstrate the existence of continual deposition between different locations of excavatable deposits , plus the limits of those deposits and their depth and volume have not been determined. On Page 4 . 9-4. while it might be desirable to have the artifacts curated at a public repository. under California law they belong to the landowner. This statement should read