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�,:4•`sr EVALUATION OF THE CULTURAL RESOURCE STUDY BY MILLS ASSOCIATES OF THE PROPOSED BUCKEYE',(1�;"':j;;j:;;:' RANCH SUBDIVISION : :� ...' " The following evaluation for the Catwil Corporation is based on a review of the cultural resource portions of the Administrative Draft Environmental Impact Report SCH#91012103 of the proposed Buckeye Ranch Subdivision. Also reviewed was the draft report Archaeological Field Investigation Buckeye Ranch Projtct Phase I Study. The above reports were prepared by Mills Associates for the County of San Joaquin and is dated December 1991 . Two visits were made to the project location , by Professor Jerald Jay Johnson in January 1992 (one for a four hour period January 3 , 1992 and the other for approximately three hours on January 24 , 1992 ) . An additional visit to the project occurred on March 13 . 1992 for an additional three hour period . These visits were part of a review of the cultural resources and the above referenced report that was requested by Joseph di Cristina, Vice President of Robertson Homes , a division of the Catwil Corporation . The March 18th visit was also to acquaint various individuals from the Native American Community with some of the cultural resources within and adjacent to the project . These visits provided a feeling for the landscape and the location of the various aspects Of the proposed development and their relationship to project maps and reports . On the second visit eleven soil samples were collected from various locations in the project for chemical testing . The cultural resources record search and other information assembled by Peak & Associates , Inc . was also reviewed as were data generated by the archaeological consultants Of Mills and Associates and other pertinent published and unpublished data. After reviewing the draft environmental impact report it is clear that the consulting archaeologists were familiar with the prehistory of the delta region in only a generalized manner . The C64 sources most often cited are of a secondary nature and often contain inferences which are not consistent with what is currently known about this part of California . In addition assumptions are made concerning the prehistory of the Tracy Lake locality which are unsupported by the data chat was assembled by the consulting archaeologists in their Phase I Study. Their presentation refers to eight sites on numerous occasions —1 without specifically indicating what these eight sites are or C65 indicating exactly were they are located. They compress these identified resources into what they consider to be two cultural -resources . - One is referred to as the "RIVER SITE" ( comprised of CA-SJO-43 , -44 , and -45 [perhaps also including -421 and the lake site ( CA-SJO-11 , -13 , -15 , -47 , -147 ) . According to the locations given in Schenck and Dawson ( 1929 : 313 ) and on the site records on file at the Central Information Center ( which was derived from Schenck and Dawson ; CA-SJO-42, -43 , and -44 are C66 outside of the project as depicted on the maps accompanying the draft E . I . R. and in the Phase I Study. On the March 18 , 1992 visit to the project , in accompaniment with a representative from the Native American Heritage Commission , the recently plowed field to the southeast of the reforestation location was visited . It became apparent immediately that this was the location of a III-$1