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The commenter's soil chemistry methodology is questionable for the following reasons: • No control sample is given; • Natural phosphate and carbonate levels for the area are not given; • Color values are subjective; • Actual results of chemistry levels, i.e.,mg per kg,are not given and,therefore, "values" can be construed as subjective; • pH levels of 6.2-6.5 have not been shown to be especially "acidic%these levels are close to neutral, 7; • pH data contradicts phosphate data. The four test sites referenced in the commenter's letter are slightly alkaline,not acidic as stated. These pH levels fall within the range of slightly acidic to mildly alkaline. General statements are made based upon minor soil differences. C84: As the commenter is aware, a Phase I study generally locates the presence or absence of surface cultural material and does not attempt to define exact location or boundaries,age,depth,integrity or significance. All of these are usually determined in a Phase II study. The DEIR investigation was an initial, Phase I study, for which the purposes are made explicit in the abstract and introduction of the technical report. The commenter should refer to page A-2, Archaeological Field Investigation, Buckeye Ranch Project, Phase I Study, where the DEIR archaeologists stressed the limited scope of work proposed, and the statement regarding the necessity for "additional historical research and field investigation for adequate interpretation of the highly significant prehistoric sites." The commenter is referred to Section 6 of the technical report, in which Phase II investigations are recommended. C85: Site CA-SJO-0240 was recorded by the DEIR archaeologists, Benjamin Ananian and Carolyn Rice, on March 21, 1992. C86: Surface cultural resources identified within the proposed development plans are provided in the DEIR. As called for in Mitigation Measure 4.9-1(d),additional surveying is required to identify the boundaries of individual use sites. Once this has been completed, developable portions of the project site can be identified. C87: This is a statement of opinion. On April 4, 1992, the Central California Information Center assigned the State Trinomial numbers to every site record submitted by the DEIR archaeologists, which validates the research methodology questioned by the commenter. C88: The statement in the report reads, "The site is associated with a series of events that led to the development of the Central California Taxonomic System." Richard Beardsley's 1954 study, Temporal and Areal Relationships in Central California Archaeology, combines the Delta sequence with the prehistory of the San Francisco Bay region which, in turn, led to the development of the Central California Taxonomic System. Please refer to Dr. Michael Moratto's publication, California Archaeology, page 181. The commenter's statements regarding significance of the complexes at Tracy Lakes indicate a lack of data for these complexes and, therefore, seem to support the recommendation for further archaeological testing at these sites. C89: Previously published reports (Moratto, 1984) indicate that these sites may be as old as 13,000 years. Also, refer to Figures F1 and F2 in Appendix G of the DEIR. The significance of other III-171