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BUCKEYE RANCH ( 4-1-92 ) 9 sites were planted in vineyards and asparagus it is possible C91 their integrity has been compromised severely but probably not anymore than that of the lumped "TRACY LAKE SITE" . _I On what basis is Tracy Lake defined as a pluvial lake that would have provided an abundant resource base for PaleoIndians . The lake size is so small and ephemeral it bears no relationship to the large well defined pluvial lakes found elsewhere in California. In addition the Sacramento/San Joaquin delta did not begin to form until within the last 4500 years thus the marsh lands currently to the west were dry land with associated river channels . It is likely that earlier peoples living or passing through the area would have travelled further west and that . as Moratto ( 1934 ) has stated . the older sites may be under the C92 alluvial soils and delta peats . At the University of California, Davis campus buried soils radio carabon dated at just over 4 . 000 years ago . in the Highway 113 road cut , are below eight to ten feet of alluvium. It is clear therefore that the resource base and conditions at and around what are now the Tracy Lakes was quite different several thousand _Years ago . Based on current information it appears that very little was going on in the Tracy Lakes locality until quite recently prehistorically. The location of a potentially older prehistoric site , based on soil chemistry. might represent an earlier occupation sequence in the locality but this remains to be defined . 3 ) . The suggestion in the Cultural Resources section of the E . I . R. that three of the cultural resources identified by the consulting archaeologists were relatively undisturbed is clearly in need of reevaluation . The "TRACY LAKE" site defined by the consulting archaeologists as a single site has been virtually destroyed in some aspects . Portions of midden deposits have been used for borrow and for levee construction . One midden remnant C93 on the south shore of South Tracy Lake probably exists only because it has a telephone pole in it . The rest of the deposit had been bulldozed away. Extensive vandalism apparently occurred and CA-SJO-147 and probably at other locations as well . Within the tree line at Brovelli Woods there is extensive evidence of land disturbance in the past and in some places there are large deep elongated pits and trenches which may represent periods in the past when the Mokelumne River overflowed in the woods and washed out areas of unconsolidated alluvial deposits . 4) . In chapter 3 the suggested mitigation measures are most often inappropriate since the consulting archaeologists have not defined were the cultural resources are in relationship to the proposed developments within the project . To make broad generalizing site boundaries and then suggest that everything within those areas should be eliminated is suggesting a precedent that would preclude any type of development within the vicinity C94 of any riparian habitat in San Joaquin County or elsewhere . If the specific boundaries of each midden deposit is defined and isolated features and artifacts taken into consideration it is possible that the archaeological resources can be protected without eliminating completely any development on the shores of Tracy Lake . On Page 3-16 it is implied that the only way to ovoid significant impact to the archaeological sites is to basically leave the area undisturbed with no development on or in the vicinity of the four locations identified by the consulting archaeologists . The sites have already been heavily impacted by III-