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BUCKEYE RANCH ( 4- 1 -92 ) 3 reporting of the site deposit as the same as the surrounding Cgs soils when in fact middens are quite distinctive and do not have the same chemistry or texture as the surrounding soils as demonstrated above . In addition there are numerous other errors that need to be corrected. 2 ) . The discussion on the background of the prehistory of the Tracy Lake area is totally inadequate and misleading.: It is stated that the Tracy Lake sites played a significant role in the formulation of the Central California Taxonomic System of cultural classification . This is simply not true . The C88 Windmiller Culture ( Early Horizon ) was defined on the bases of sites south of the Mokelumne River and one site on the Cosumnes River since little if any material of this age has been found at Tracy Lake . The Middle Horizon was defined almost entirely on the basis of archaeological sites in Sacramento County and no evidence of any significant amount of material of this antiquity was found in any of the sites at which excavations were conducted within the project boundaries . The Late Horizon was also defined for the most part on sites within Sacramento County and none of the site numbers cited within the proposed Buckeye Ranch Subdivision were ever mentioned in any of the publications which defined the Central California Taxonomic System. There is constant reference to one projectile point base and one crescent that are supposed to represent the possibility that the Tracy Lake locality may have been used as early as 13 , 000 years ago by PaleoIndians . Neither of these specimens were found in archeological deposits . The point base was on the surface and the crescent was in the Mokelumne River Channel . Heizer in a 1938 C89 article indicated that many projectile points found within the Early Horizon (Windmiller Culture ) have a similar form and basal grinding and thinning not inconsistent with the specimen from Tracy Lake . He indicates that it could just as easily date within the last 4500 years . It is possible that this point was picked up by much later inhabitants of the Tracy Lake locality from the older sites across the river and closer to Thornton._ Crescents in California generally date between 7 . 500 to 9 , 000 years ago , but a single specimen out of context does not really tell us much about its potential significance or antiquity . In actuality the excavations by Dawson in the 1920s and those by Mcgeein and Moyer in the 1970s clearly suggest that most of the prehistory that has been defined occurred within the last 500 to 1 , 000 years . FThe archaeological consultants also use all inclusive terminology when discussing cultural resources which is not appropriate . They indicate that the cultural resources at Tracy Lake are- the C90 last relatively intact prehistoric sites in San Joaquin County. This is simply not true . San Joaquin County extends into the Sierra Nevada foothills and one of the largest collections of archaeological sites in California occurs within this region. Since much of this foothill country contains riparian habitat and most likely numerous archaeological sites which have yet to be recorded it is likely that a substantial number of sites still exist . In addition while contemplating a possible Ph .D . dissertation project from Camanche Reservoir to the Delta this reviewer visited some very large prehistoric sites on the south C91 side of the Mokelumne River which were far larger than anything viewed at Tracy Lake . Some of those sites had very deep deposits and some of the associated valley oak trees were over four feet in diameter . Since this was 23 years ago and since many of these IH-88