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Soil Investigations for Data Collection in the Delta Initial Study/Proposed Mitigated Negative Declaration 193 As a result, multiple tribal cultural resources were identified within the region of the Study Area, with two within the Study Area according to GIS maps and multiple being within a quarter mile. The tribe expressed that these locations need confirmation via survey work and requested that the pre-activity site visits and associated cultural survey as outlined in MM-CUL-1 be conducted and findings reported to them before activities start. In accordance with MM-CUL-1, should the resources be confirmed the locations of the soil investigations will be moved or not conducted in order to avoid any impacts to the resources. Information specifying the location, nature, or use of these areas is not provided in this IS/MND do to the confidential nature of tribal cultural resources submitted by the tribe through the consultation process (Public Resources Code Section 21082.3(c)(1)). Multiple tribes expressed that they could not specify any particular tribal cultural resource locations due to the fact they have not had physical access to much of the Study Area previously and/or do not have the location of cultural resources that are potential tribal resources. Given this, some tribes requested to be able to coordinate visiting the soil exploration locations during the pre-activity field visits when the archaeological survey is occurring, or else be informed of the results of the surveys after they occur. Additionally, concerns were expressed related to soil explorations that occur within levees, and requests were made to be contacted in case resources were identified during survey, monitoring, or sampling. Cultural sensitivity training was also requested for the Proposed Project. A request for tribal monitors to be present anytime an archaeological or environmental monitor is present was also made. This project would not, however, have archaeological or tribal monitors for the actual soil exploration activities. Monitoring for cultural and tribal cultural resources is only effective when the project is occurring adjacent or on the location of a resource that has been previously identified and the monitor is able to prevent the resource from being disturbed, and/or when it is possible for the monitor to effectively observe the soil being removed from the earth during an activity likely to produce a substantial impact to a previously unidentified cultural or tribal cultural resource in the subsurface. In this case, the existing project design and mitigation measures render monitoring ineffective for prevention of significant damage to resources. The reasons for this are as follows: 1. Resource identification efforts on the surface during pre-activity site visits would be guiding avoidance for any resources identifiable on the surface and will be moving or removing soil exploration units in order to prevent disturbances to cultural resources or potential cultural resources. This is in accordance with mitigation measure MM-CUL-1. 2. A CPT does not extract any soil, though it does penetrate the ground. A monitor monitoring for cultural material at a CPT location would not be able to identify any subsurface resources despite the soil disturbance. The diameter of a CPT (1” to