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I within the project, the `River site." With a proper cultural study this unfortunate occurrence and Cb0 (`potentially other unwitting blunders will not happen. It is stated in the cultural resources section that archaeological studies that have been undertaken determine that the Tracy Lakes are pluvial lakes and the vicinity was inhabited 13,000 years ago, at the end of the Pleistocene epoch. It states that the project site contains eight recorded prehistoric archaeological sites listed with the California Archaeological Inventory Central Information Cbl Center. In reading through this cultural resources section we find the most telling statement the acknowledgement by the Draft EIR authors that, "the Tracy Lakes complex is one of the few aggregates of sites in central California that qualifies as an important archaeological resource under all five of the CEQA criteria that apply to prehistoric archaeological sites." They further suggest that stone artifacts recovered from the Tracy Lakes complex have been continually referenced in the anthropological and archaeological literature as some of the oldest in the country and it is perhaps thel 9 oldest, largest and best preserved example of a stratified five cultural complex of sites in San Joaquin County. There is also the acknowledgement that the integrity, uniqueness, postulated age, size„ setting and research value, in addition to native American concerns and implications of their interrelationship makes the Tracy Lakes complex eligible for inclusion in the National Registry. We suggest that a CEQA and Health and Safety Code Section 7050.5 violation has already been perpetrated by the developers at the site. In regards to the discovery of human remains, CEQA appendix K, Section VIII, states, "In the event of discovery or recognition of any human remains in C92 any location other than a dedicated cemetery, there shall be no further excavation or disturbance of the site or any nearby area reasonably suspected to overlie adjacent human remains." The cutting down of thousands of oaks in the riparian forest to accommodate the developers golf course layout and the subsequent stump removal may in fact have violated the above requirements. We will seek counsel on this issue and think it is an appropriate consideration of the developers, the County and the EIR consultants, while this effort of risk assessment is underway.. We share the lone Band of Miwok's concerns over desecration of archaeological sites in the project site important to their traditional history and culture. They have also raised questions that C53 appear to cloud title to this Brovelli Woods/Tracy Lakes property. We are aware that they are currently undertaking research in an attempt to prove that the project site was deeded to the Miwoks as part of the Mexican land grant - San Juan de los Moquelumnes. Joan Villa, the tribal administrator of the Ione Band, has also suggested that the Miwck tribe and chief Charly Maximo received this land for Indian labor that was supplied to John Sutter in Sacramento. With all due respect to the Community Development Department, biotic and cultural resource mitigation monitoring by the County, or supervising of this monitoring by the County, is a pipe-dream. Cso This fact and the inability of the County to properly monitor projects requiring biotic and cultural resource monitoring is proven by the County's prior failures to monitor mitigation measures made a part of project approvals. We point out as example unfortunate occurrences in the County's monitoring of the Claude C. Wood quarry project. The Department does not have the staff to engage in the regular monitoring prescribed in the Draft EIR. CIt appears that this Buckeye Ranch Subdivison proposal is inconsistent with the existing III-74