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Ms. Kerry Sullivan April 8, 1992 Page 19 These suggestions appear to go well beyond what is necessary or appropriate, according to the MiWok tribe representatives and Dr. Johr.son. Roadway and house development should avoid actual cultural C221 sites, or where not feasible, encapsulate burial sites. It is difficult to understand,for instance, how the golf course would disturb burial sites as long as they are not physically violated. Paae 4.9 - 12 Mitigation 4.9-1(c) A qualified archaeological monitor with the following requirements must be present during all land altering or excavation activities. Shall have at a minimum a B.A. or equivalent and one year field experience,and answer to a professional archaeologist. C222 Shall be independentof any Native American monitor present. Shall have the authority to stop construction activity within 10 metl;rs of any cultural material uncovered until that find has been adequately mitigated to his satisfaction, or the project redesigned. Why should there be an archaeological monitor independent of any Native American monitor? The Native Americans have cultural ties to the remains unlike the archaeologists. The standards for "adequately mitigated to his satisfaction or the project redesigned" must be C223 determinedprior to certification of the Environmental Impact Report. -1 Paae 4.9 - 13 i Impact 4.9-2 Development of the site would increase access to the sites resulting in increased vandalism of the cultural resources. Housing and recreation maintenance activities would likely result in degradation of this complex with the relocation, repair or addition of subsurface utility and sewage lines,and by the soil compaction and irrigation of golf and equestrian activities. C224 In the past, archaeologists excavated the property and stole artifacts from the remains. The owners are proposing a Management Plan that would be used to administer an environmentally sensitive project which will provide the correct long-term stewardship that these remains deserve. Paae 5 - 1 Significant Impacts All significant impacts can be mitigated to a level of insignificance with the exception that the impairment of the scientific potential of the cultural resources cannot be mitigated by capping the site or excavating a portion of the affected area. C225 Why can't capping the site with aarth be used as a mitigation measure for the impacts on cultural resources? This is a mitigation method has been previously recommended and used by archaeologists for preservation of archeological resources and one that this Environmental Impact Report author recommendedfor use on the road through the project as suggested on Page 3 - 16. III-134