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MHY-14-lyy� IY:20 FKUM Mills Hssociates TO San Joaquin Co P.13 BUCKEYE RANCH (4-1-92 ) 13 today. Most of the oak trees and other vegetation either did not exist at that time or these existing plants were quite small . Many of the Mitigation Measures suggested on pages 4. 9-10 through 4 . 9-13 would be appropriate if conditions were as the consulting archaeologists have portrayed. Since the situation at the proposed Buckeye Ranch Subdivision is in fact quite different it is not appropriate to make specific recommendations concerning potential impact on sites at this time . All of the cultural resources have not been -located, the limits of the excavatable archeological deposits and potential burial areas have not been delimited and appropriate field techniques were not employed which would yield the kind of data needed to base sound and reasonable mitigation proposals . RECOMMENDATIONS 1 . All of the cultural resources that might be impacted by the Proposed subdivision need to be precisely located. 2, The lumping of large numbers of isolated cultural resources into large sites is appealing philosophically and may actually reflect the Native American use of the area but it does not provide the specific location of archaeological materials that will be impacted. In reality the Indians used the entire area during the late prehistoric period and perhaps as late as the 1840s . thus it could be argued that the whole project should be recorded as one site and this is simply not reasonable . The specific location of excavatable deposits need to be identified and recorded in a responsible and professional manner. The resulting site records should meet *and/or exceed those standards in the "Handbook" established by the State Historic Preservation Office . This document is available from the eleven Information Centers and the State Historic Preservation office and the most recent March 1989 version should be used. The boundaries of the excavatable sites should be determined through soil chemical tests , and the depth should be determined with several auger holes at each location identified. These sites should then be placed on a master map that would be provided to the property owners , the San Joaquin County Planing Department . and to inaiviauais •wno nave a need to rnow. when conducting additional studies or when it is necessary to avoid resources during construction. 3 . The .Native American Heritage Commission should be contacted to determine who would be the appropriate Native American individual or group to consult concerning the proposed Buckeye " Ranch Development . Representatives of the indicated Indian group should be consulted and their input sought regarding the project and any changes that may occur. 4 . Any group of consulting archaeologists should include at least one. individual who has had several years of archaeological field experience in decision making roles . This individual should also have considerable experience in the excavation of mounds in central California. not the northwest coast . desert regions . Sierra Nevada, American Southwest or some other location were the nature of the soils and cultural features and artifacts are different .