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been conducted and most of the prior archaeological work was undertaken by amateurs who only examined a very limited area. We think it is fair to say that the site identification is random at best. Depending on this work by amateurs to make an accurate cultural analysis seems to limit the reliability of the current study. Dr. Bennihoff suggested that not enough current studies of the site Cos have been conducted to adequately make informed judgements on the appropriateness of a subdivision project that may in fact have significant irrevocable adverse impacts on the cultural integrity of the site. He emphasized the uniqueness of the area in archaeological significance, because it contains multiple sites with continual use patterns to pre-history. I He further suggests that the ethnography of the site has never been sufficiently analyzed. Dr. Jerald Johnson, a project consultant archaeologist, from California State University, mentioned in a phone conversation that the recent field survey and cultural resources report missed some important sites and was generally an inadequately prepared document that limits the management plan by inadequate information. The current assessment by Mills and Associates appears to be a good general effort and I found C47 enlightening, and I compliment them, but it clearly falls short of what is necessary to adequately determine if the project can in fact coexist with protection of the cultural integrity of the site. We feel it is imperative to conduct a comprehensive archaeological investigation of the site before any further land use determination and planning consideration is made, not after the project is approved. With this information a reasonable and enlightened decision can be made. To not do so, will be making a critical decision on rudimentary information, which may lead to the desecration of this one-of-a-kind site. The results of the current archaeological field study, 28 October 1991 to 22 November 1991 , performed by Benjamin Ananian and Carolyn Rice, of Mills Associates, reveal that no boundaries were found to separate the five Tracy Lakes sites recorded in the past. This indicates that these and other cultural sites are not localized, but scattered throughout the project site. In other words, the C48 project will have adverse impacts on cultural sites no matter where the project proponents propose to locate the houses and the golf course. The project developers are suggesting that development can be located away from archaeological sites. This suggestion is illogical when considering this determination that significant sites have no boundaries and are scattered throughout the project site. We note that there seems to be three major sites, the "Lake site," the Village of Seuamne,"� and the "River site." We feel that state and federal laws may be applicable for the protection of these C49 and other sites within the project boundaries. We think it would be appropriate to consider and address these state and federal protection measures for cultural resources in the study and in the Draft EIR. To indicate the problems that can manifest themselves without a properly conducted archaeological inventory and comprehensive study, we point out the reforestation project currently underway on the project site. The developers, in an act of good faith to counteract the negative C50 publicity generated when they cut down thousands of oak trees to accommodate their golf course layout, began a reforestation project near the Mokelumne River at the south end of the project boundary. It has since been determined that this good faith gesture was improperly undertaken because the reforestation project is taking place in one of the most significant archaeological sites III-73