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Element 9 of the RTMP

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#1 · (Edited)
Can someone that is a bit more pc savy post up the currnet proposals sent to the FOTR list I will admitt that I do not have much pc skills

Rusty

These are the drafts that are going to be submitted to the ROC this thursday they went out on the FOTR list but have not got much feedback yet that is the reason that I asked for them to be posted here in this Forum
 
#2 ·
Rusty,

I hope this works!

Both Free and Fee are included.

Dennis

ELEMENT 9 (Free): Permits and Requirements

Overview – A free permit will be required for each motor vehicle and operator using the Rubicon Trail System. This permit entitles a vehicle and operator unlimited access to the Rubicon Trail System within a given calendar year. Any operator failing to obtain and carry a permit will be subject to fines.

The area requiring a permit is bordered by the spillway at Loon Lake, east of the Wentworth Springs campground and the El Dorado County line on the east side of Rubicon Springs. This includes the Ellis Creek Trail across “The Bowl” and any variants along the trail.

El Dorado County requires that operators carry the permit in the vehicle at all times while on the Rubicon Trail System.

Initially there will be no limit as to the number of permits issued each year or allowed each day.


Objectives: (in alphabetical order)

9.1 Accountability:
This permit system places the user accountable for his/her actions while on the trail. An agreement will be signed requiring the operator of the vehicle to promise to Tread Lightly, act responsibly and obey applicable laws.

The agreement will also specify some local laws and associated fines. It will be the operator’s responsibility to know all applicable laws for the area.

Violations of any laws, ordinances or Trail Use Agreement are subject to fines.

9.2 Banning trail/resource abusers:
The County may ban individuals from driving the Trail for any period of time (a month, a year, or for life). Individuals who have been banned from the Trail and attempt to circumvent this system shall be fined (suggested $1500).

9.3 Education:
Each permitted operator shall sign an agreement that details how to Tread Lightly, drive and camp responsibly, and how to prepare for a trip across the Rubicon.

The agreement will summarize local state and federal laws pertaining to the Rubicon Trail. This will not be a complete list. The operator will be responsible for knowing and obeying all applicable laws.

Brochures from the BlueRibbon Coalition and other organizations will be provided that will cover many topics related to driving an OHV.

The permit paperwork will include a list of recommended travel needs. This will not be a complete list of what may be required on your journey but simply a recommendation (e.g. spare tire, first aid kit, jack, fire extinguisher, etc.).

9.4 Feedback:
The application will have a section for the user to give feedback.

The list of trail users will allow the county to send out mailings of questionnaires except for those opting out.

The application paperwork will include information on how to get in touch with the officials responsible for the health and future of the Rubicon Trail.

9.5 Governing Bodies:
(list addresses, phone numbers and e-mail addresses)
County
El Dorado
Board of Supervisors
Airports, Parks and Grounds
Department of Transportation
Rubicon Oversight Committee

Placer
Board of Supervisors
Department of Transportation

State
California State OHV Commission
CRWQCB Lahontan District
CRWQCB Sacramento Valley District

Federal
Eldorado National Forest
Tahoe National Forest
Lake Tahoe Basin Management Unit

9.6 Grant writing information:
The information collected from the application and subsequent questionnaires can be used to document trail use for grant writing.

9.7 Permit Application: see attached

9.8 Pool of possible trail volunteers
The Rubicon Trail relies on volunteers to stay healthy. Historically, local clubs have adopted sections of the trail to maintain. The permit application will provide a list of possible volunteers. This list of volunteers should be generated, maintained and updated by El Dorado County. The County could handle the management of the list of volunteers or may turn that over to FOTR or the Rubicon Trail Foundation (RTF).

9.9 User counts:
The application process will provide a count of permits issued of motor vehicle trail operators each year, but not a real count of actual trail use.

The possibility exists in the future to use bar codes or other technology to count each individual trip to the Rubicon Trail.

9.10 User profiles:
The application will provide a basic data base of the operator and his/her vehicle(s). The permit could provide details of anticipated use, vehicle description and modifications, user information, feedback about trail experiences, club affiliation, etc.

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ELEMENT 9 (Fee): Permits and Requirements

Overview – A permit will be required for each motor vehicle using the Rubicon Trail System. This permit will require a small fee which entitles a vehicle access the Rubicon Trail System an unlimited number of times within a given calendar year. The area in requiring a permit is bordered by the spillway at Loon Lake, east of the Wentworth Springs campground on the original trail and the El Dorado County line on the east side of Rubicon Springs. This includes the Ellis Creek Trail across “The Bowl” and any offshoots along the trail to access camping areas.

Issued by El Dorado County, each sticker will be assigned serial number and possibly a bar code. The permit is issued to a vehicle and its driver. Initially there will be no limit as to the number of permits issued each year or allowed each day. See Element 8 for information on trail capacities and the possibility limiting the number of permits available.



Objectives: (in alphabetical order)

9.1 Accountability:
This permit system places the user accountable for his/her actions while on the trail. An agreement will be signed requiring the operator of the vehicle to promise to Tread Lightly, act responsibly and obey applicable laws.

The agreement will also specify some local laws and associated fines. It will be the operator’s responsibility to know all applicable laws for the area.

Violations of any laws, ordinances or Trail Use Agreement are subject to fines.

9.2 Banning trail/resource abusers:
The County may ban individuals from driving the Trail for any period of time (a month, a year, or for life). Individuals who have been banned from the Trail and attempt to circumvent this system shall be fined (suggested $1500).


9.3 Education:
Each permitted operator shall sign an agreement that details how to Tread Lightly, drive and camp responsibly, and how to prepare for a trip across the Rubicon.

The agreement will summarize local state and federal laws pertaining to the Rubicon Trail. This will not be a complete list. The operator will be responsible for knowing and obeying all applicable laws.

Brochures from the BlueRibbon Coalition and other organizations will be provided that will cover many topics related to driving an OHV.

The permit paperwork will include a list of recommended travel needs. This will not be a complete list of what may be required on your journey but simply a recommendation (e.g. spare tire, first aid kit, jack, fire extinguisher, etc.).

9.4 Feedback:
The application will have a section for the user to give feedback.

The list of trail users will allow the county to send out mailings of questionnaires except for those opting out.

The application paperwork will include information on how to get in touch with the officials responsible for the health and future of the Rubicon Trail.

9.5 Funding:
The intent of the plan is to capture sources of funding related to Trail use such as grant money and tourism funds. The intent of this section is to clarify that the Trail Use Agreement fee (if implemented) would not be the sole source of funding for management of the Trail.

The suggested cost of each permit is $20. Preliminary user polls indicate that this fee would be marketable to most trail users.

Exemptions - El Dorado & Placer County, state and federal vehicles. All vehicles will require a sticker. Exempt vehicles will obtain a permit at no cost, no exceptions. This permitting system applies to motor vehicles only, thus mountain bikers and hikers will not require a permit. Motorcycles and quads will require a permit.

Private land owners need to be provided reasonable access to their property in accordance with this Plan and applicable law.

Commercial enterprises and Limited Time Users: a sticker for each vehicle on the trail still applies; however commercial users and limited time users will be provided a reduced cost fee and group permit system. In-kind service/donations should be attributed to fee reduction for large groups and commercial operations.

Funds collected in the name of the trail or as part of any permit system, will go to the trail. The burden/cost of issuing the permits is on El Dorado County. No more than 33.3% (suggested) of the monies collected will go toward the salaries of trail workers/supervisors. The rest will fund projects on the trail.

9.6 Governing Bodies:
(list addresses, phone numbers and e-mail addresses)
County
El Dorado
Board of Supervisors
Airports, Parks and Grounds
Department of Transportation
Rubicon Oversight Committee

Placer
Board of Supervisors
Department of Transportation

State
California State OHV Commission
CRWQCB Lahontan District
CRWQCB Sacramento Valley District

Federal
Eldorado National Forest
Tahoe National Forest
Lake Tahoe Basin Management Unit
9.7 Grant writing information:
The information collected from the application and subsequent questionnaires can be used to document trail use for grant writing.

9.8 Permit Application: see attached

9.9 Pool of possible trail volunteers
The Rubicon Trail relies on volunteers to stay healthy. Historically, local clubs have adopted sections of the trail to maintain. The permit application will provide a list of possible volunteers. This list of volunteers should be generated, maintained and updated by El Dorado County. The County could handle the management of the list of volunteers or may turn that over to FOTR or the Rubicon Trail Foundation (RTF).

9.10 User counts:
The application process will provide a count of permits issued of motor vehicle trail operators each year, but not a real count of actual trail use.

The possibility exists in the future to use bar codes or other technology to count each individual trip to the Rubicon Trail.

9.11 User profiles:
The application will provide a basic data base of the operator and his/her vehicle(s). The permit could provide details of anticipated use, vehicle description and modifications, user information, feedback about trail experiences, club affiliation, etc.
 
#4 · (Edited)
How will people be able to apply? There are going to be a LOT of people who go that will not know about the permit process and that will cause a lot of problems.

Consider:

A new user shows up at the spillway, only to find that he needs to apply for a permit to pass through. He has spent hundreds on camping gear, thousands upgrading his vehicle as well as the time making his vehicle trailworthy but has to turn around and go home however many hours he has driven up there because he doesn't have a sticker.

IMO, it seems to exclude the majority of people who use the Rubicon. Why pay for a season pass if you only go once or twice? I doubt that people are going to obey these new rules if there is no one to enforce them, and $20 per vehicle per year will not create enough revenue to fund Law enforcement patrols in an area that doesn't have it already.

I believe that a per day use pass is a necessity, with a seasonal use pass an option for those who would want it. Otherwise we would alienate the occasional user, as well as those who do not plan ahead by applying for a sticker ahead of time.


EDIT: after re-reading I feel I need to clarify: I understand that it states the burden of issuing is on FS, however, without add'l money to have someone at each trail entrance issuing permits and admitting access, LEO's can not reach all points of the trail to enforce this mandate.
 
#5 ·
makya said:
How will people be able to apply? There are going to be a LOT of people who go that will not know about the permit process and that will cause a lot of problems.

Consider:

A new user shows up at the spillway, only to find that he needs to apply for a permit to pass through. He has spent hundreds on camping gear, thousands upgrading his vehicle as well as the time making his vehicle trailworthy but has to turn around and go home however many hours he has driven up there because he doesn't have a sticker.

IMO, it seems to exclude the majority of people who use the Rubicon. Why pay for a season pass if you only go once or twice? I doubt that people are going to obey these new rules if there is no one to enforce them, and $20 per vehicle per year will not create enough revenue to fund Law enforcement patrols in an area that doesn't have it already.

I believe that a per day use pass is a necessity, with a seasonal use pass an option for those who would want it. Otherwise we would alienate the occasional user, as well as those who do not plan ahead by applying for a sticker ahead of time.


EDIT: after re-reading I feel I need to clarify: I understand that it states the burden of issuing is on FS, however, without add'l money to have someone at each trail entrance issuing permits and admitting access, LEO's can not reach all points of the trail to enforce this mandate.
I think the real question is if someone was to say screw the pass and go on the trail with a try to catch me attitude, what would the fine be? and would it be a moving violation?

I think a day pass is a waste of time, that would create more problems we would almost need a toll collector then.
 
#6 ·
IMHO, we should roll any documentation in as an option first, before making it a requirement -- we need to educate well before enforcement starts. The application process would be much in line with the existing USFS Fire Permit, which can be sourced at ranger stations, from local stores, or from volunteers. Hopefully the FOTR Kiosk volunteers would be able to write them out, as well. The easier it is, the better compliance will be.

We've tried to make it enforceable, but at some point, as with the USFS Fire Permit, there will be enforcement. Similarly, there may be plenty of folks on the trail without a permit, but they take their chances doing so, and if County or USFS staff finds them, they can be ticketed. Violaters should be warned at first, but as word gets out, fines will be levied.

At some point, after significant effort for enforcement, users need to be responsible for knowing the rules, and if they choose to 'wheel without a permit, take the chances on getting caught and fined. Ignorance will become an increasingly poor excuse ...

Randii
 
#7 · (Edited)
IMHO, after attending countless meetings, it is unrealistic to believe that the County will not create SOME sort of paperwork/permit. Accordingly, I've put my effort into encouraging two options:
* a free document, along the lines of a USFS Fire Permit (by far, this is my preference)
* low-cost alternative (an effort to stay any efforts for a high-cost model where the trail users are forced to bear the full costs of increased services)
Fighting against either of these plans IMHO risks the County stepping in with its own plan, which IMHO would likely have much higher costs with worse restrictions.

$20 is cheap.... not even a full gas tank on most 4x4s. It is IMHO a cheap nod of cooperation to the County that gets some good guidelines in the RTMP that should help avoid steeper costs down the road.

:mad3: Devil's Advocate :mad3:
By cooperating to create a fee structure, we may create a mechanism that the County can later ratchet up the cost...


IMHO, the County could already do that, and cooperating with them to pass a favorable RTMP establishes guidelines is a good, cheap hedge that will make it harder for costs to skyrocket later. The guideline I refer to is in the text Dennis posted:
The intent of the plan is to capture sources of funding related to Trail use such as grant money and tourism funds. The intent of this section is to clarify that the Trail Use Agreement fee (if implemented) would not be the sole source of funding for management of the Trail.
Getting better demographics on trail users will help FOTR, RTF, and the County pursue better grants/funding.
Stating this guideline up front IMHO makes it less likely that the county will try to fund themselves entirely based on user frees, which would wind up being MUCH higher than $20.

Randii
 
#8 ·
"IMHO, we should roll any documentation in as an option first, before making it a requirement -- we need to educate well before enforcement starts. The application process would be much in line with the existing USFS Fire Permit, which can be sourced at ranger stations, from local stores, or from volunteers. Hopefully the FOTR Kiosk volunteers would be able to write them out, as well. The easier it is, the better compliance will be."

I agree Randy any documintation should be an option at first,as far as education goes I think the drafts need in writing a Grace period for at least a year go ahead and install the Iron rangers with a SIMPLE two part permit that users can fill out at the trail heads and if they do not fill one out then when the LEO's or the SO's or the trail patrol asked them to see there copy of the permit that sii the time that the officers can educate the user of the permit system and go ahead and issue them one.

We've tried to make it enforceable, but at some point, as with the USFS Fire Permit, there will be enforcement. Similarly, there may be plenty of folks on the trail without a permit, but they take their chances doing so, and if County or USFS staff finds them, they can be ticketed. Violaters should be warned at first, but as word gets out, fines will be levied.

This is the reason for a Grace period to get the word out, The county just cannot start a permit program and expect the word to get out.Not everyone is on the FOTR list or Pirate BB

At some point, after significant effort for enforcement, users need to be responsible for knowing the rules, and if they choose to 'wheel without a permit, take the chances on getting caught and fined. Ignorance will become an increasingly poor excuse ...

"At some point" this point needs to be stated in the drafts I think at least a year

IMHO, after attending countless meetings, it is unrealistic to believe that the County will not create SOME sort of paperwork/permit. Accordingly, I've put my effort into encouraging two options:
* a free document, along the lines of a USFS Fire Permit (by far, this is my preference)
* low-cost alternative (an effort to stay any efforts for a high-cost model where the trail users are forced to bear the full costs of increased services)
Fighting against either of these plans IMHO risks the County stepping in with its own plan, which IMHO would likely have much higher costs with worse restrictions.

I agree the county will establish some kind of paperwork that this is our chance to have our say in it, but whatever comes out of the county has to simple and easy to get. I'm just afraid that permit system thru the county will end up being a long drawn out process that requires approval that takes a year which will lead to more rulle breaking on so on.

"$20 is cheap.... not even a full gas tank on most 4x4s. It is IMHO a cheap nod of cooperation to the County that gets some good guidelines in the RTMP that should help avoid steeper costs down the road."

20.00 bucks is pretyy cheap compared to what we spend on our rigs

Thanks Randy and the others that came up with these proposals I'm not a big fan of fees and permits and I think the least resticted way is for the better But my main point is that there has to be time to implement the permit system so that the word (education) gets out to evryone that uses the trail.

Rusty
 
#9 · (Edited)
Thanks guys, this makes a lot more sense to me seeing some of your opinions.
I do think that an Iron Ranger is a better idea than a seasonal sticker.

Also, how soes this work with their "proposed" capacity limits? Is this just a preliminary to hopefully circumvent the limits by showing responsible #'s of users?

And about enforcement; I realize that every plan requires more manpower for LE, but how do we address this when the ROC members on the Enforcement end of it bring this up? they are short on manpower already, and I think the county sees limits on #'s easier to maintain.


I should also state; I am by no means trying to argue or say this won't work, and I do hope that most of this goes through unchanged, I'm just playing Devil's advocate here. I do have an appreciation for those who drafted this, I am sure it took a lot of work to come up with this propsal
 
#10 · (Edited)
Don't forget that Element's 8 & 9 are going to be discussed at the ROC meeting this Thursday (8:30 to approximately noon) at the Library conference room. After the discussion period there will be a vote on whether to include them into the RTMP or not (consensus is needed). If not then the oigional Elements (can be downloaded from the county website
http://www.co.el-dorado.ca.us/Rubicon/MasterPlanReports.htm} will be included into the RTMP as submitted. There will be time for public comment after that (don't know the specific dates) but it would be much better if our version was the one that was in the RTMP.
 
#11 ·
Element 8 is about the capacity/counts and FOTR hopes to affectively remove the discussion of capacity limits from the RTMP entirely.

As for the fee...a poll was done on this forum and the data broke down like this...

42%...Yes, (to fee)..."Whatever it takes"
33%...Yes, but under $10.00 per trip
13%...Yes, but doubt it will work
12%...No, Del are you nuts

Link to poll: http://www.pirate4x4.com/forum/showthread.php?t=144777&highlight=pay+to+play

Reality check...FOTR is making recommendations for changes to elements 8 and 9 of the RTMP (Rubicion Trail Master Plan) to the ROC (Rubicon oversite committee). The county has final say in the language and ultimately the county Supervisors will vote on it, but they do appear to be listening to the user groups by listening to the ROC's recommendations. Just remember they don't have to listen and the language we are submitting can be changed. Legal at the county will have to put their stamp on it too. We'll see, but please understand we are making recommedations via the ROC...we are not guarenteed to get what we ask for.

Personally, I have no issue with a permit that is like a fire permit. And, I would pay a reasonable fee that 100% goes back to the trail. Yes, it seems stupid that we have to pay extra for a county road...we don't have pay extra for using Ice house road. But this isn't Ice House road either. Its not like you can drive a maintenanc crew to any section of the trail. Yes, I'd be happy to see the county pay for all the maintenance/management of the trail that the RTMP will have in it. Again, reality seems to suggest that won't happen. The language written in FOTR's 8 and 9 revisions specifically states the county will not expect the fee (In the above fee version) to cover all costs on the trail...paraphrasing. The intent here is to make sure the county is on the hook for some funding and users are not expected to pay 100% of it.
 
#12 ·
For me the question is how do we get more people to care to look at this?? It is very important, and I've heard much complaining about not being informed. Now, here it is, but the response is low.............we've got TWO users not in the loop responding here.

If a post goes up like "Dynomite on the Con" or "Are we being censored?" Were all over it like flies on poo.

175 hits this morning and 187 now. I am responsible for two of them.

Scott
 
#13 ·
Scott,

I'm thinking the general masses don't look in the Rubicon Trail Forum because they just don't care until it hits them in the face. (blowing up Gatekeeper)

The next couple outbursts will probably be the blowing up of the Little Sluice, I didn't know I needed a permit officer, the fine is how much? Or perhaps some day when Joe 4wheeler drives 12 hours to find out that the vehicle quota has already been met and he has to join the sweat line like a duck hunter waiting for an opening or just turn around and go home :shaking:

Over 62,000 registered members on Pirate though I'm curious as to how many are fairly close to the Rubicon. It dosn't matter if other governing agencies are watching how this works out to perhaps set a precidence it's not in their backyard "yet".

Crossposts in Pirate make any difference?
Permits required to run the 'Con versus Element 9 of the RTMP for a title?
Crossposts with other boards may or may not help? (4x4, quads, dirt bike forums ect)

I still thinkpeople are basically lazy. If they do decide to click on a element 9 of the RTMP thread and see a longgggg post similar to what prtsnpcs put up (not a dig on prtsnpcs) they just arn't going to read it. Maybe put a very brief synopsis infront of the longggg post would help? Throw some oh shit type verbage "permit required", "fines" , "rigs not allowed on Rubicon" as they pertain to the topic granted that just covered all the bases.

Robert
 
#14 ·
i think this plan sucks.. reality is a majority of the users don't care.. they only wheel in the summer and any other time its locked up in the side yard. If you want public feed back a real effort should be made this summer with public contact on the trail.. I know old story, but we can't assume everyone uses this site..
 
#15 ·
My point mntbronco is even those that do use this site, come here regular, even this forum, don't have the interest to follow up on an issue that has a time deadline. It is over now so it is too late.

On the other hand, I am real happy to see any activity here this time of year. Years past this place was a ghost town till April.

The bigger point being, govrenmental agencies work all winter and our collective attention to the Rubicon diminishes during that time.
 
#16 ·
cruzila said:
For me the question is how do we get more people to care to look at this?? It is very important, and I've heard much complaining about not being informed. Now, here it is, but the response is low.............we've got TWO users not in the loop responding here.

If a post goes up like "Dynomite on the Con" or "Are we being censored?" Were all over it like flies on poo.

175 hits this morning and 187 now. I am responsible for two of them.

Scott
Speaking for myself. I'm here Scott. I have known this was coming for a long time. I appreciate all the work you have done over the last nearly 2 years working with others to tie-down the details. Somebody from our club has made it to every meeting we could along the way. We then discuss it, read other clubs reports, keep an eye on RTMP revisions, etc. I'm not saying we have scrutinized the entire plan but certainly 8 and 9 have received the most attention. I feel that Elements 8 and 9 are being well communicated and negotiated and that you are doing a fine job of getting our points across. Again, I'm speaking for myself... I have come to terms with some of the items listed in this plan and have been a proponent of other items all along. No surprises, things are coming along ok, keep up the good work.

Blowing up the gatekeeper was a big surprizing dissapointment for me and shouldn't at all be compared with the progress being made here.
 
#17 ·
cruzila said:
It is over now so it is too late.
It's not too late for Elements 8 & 9 according to Dan Bolster. The 30 day period hasn't begun so we have a little more time to review & re-write Elements 8 & 9. Doug Barr has a new sub-committe and he's looking for input. He'll be presenting "our" proposed Elements 8 & 9 at the March 9th ROC meeting.
 
#18 ·
cruzila said:
My point mntbronco is even those that do use this site, come here regular, even this forum, don't have the interest to follow up on an issue that has a time deadline. It is over now so it is too late.

On the other hand, I am real happy to see any activity here this time of year. Years past this place was a ghost town till April.

The bigger point being, govrenmental agencies work all winter and our collective attention to the Rubicon diminishes during that time.
I understand cruz,,
I deal with various gov agencies on a regular basis, and feel very worn and tied of dealing with agencies that can take years to plan something and then only allow a fraction of that time for the public to comment on it..
I'm happy with what time we were allowed to respond, but i guess not everyone has the desire and heart that you do for the trail to follow up on these issues
 
#19 ·
I think many 'wheelers may be poorly informed, but it hasn't been for lack of FOTR getting the word out... not just here but on the FOTR mail list, in the Cal4 'In Gear' and I know Del has published articles in Blue Ribbon's national magazine. Many of us have personally staffed the kiosk and participated in trail counting weekends where we encountered and talk directly to the users... we've pushed plenty, but in the end, trail users need to get out and pull the information, themselves.

More and more folks are doing that, but it is still an uphill battle! Help us spread the world -- share the information with your local wheeling buddies, club members, 4x4 stores... pretty much whoever will listen!

Randii
 
#20 ·
mtnbronco said:
...feel very worn and tied of dealing with agencies...
I hear that!

When I look back at ESP's original proposal, I'm pleased with the improvements we've helped make to it, but there's still a ways to go, and we've gotta make sure the agencies KEEP SEEING see our involvement and resolve.

Randii
 
#22 ·
Yearly permit has been discussed, and commented in writing. It remains to be seen whether it gets included in the final RTMP -- you can comment it again during the 45-day Draft EIS comment period, and they will have to respond to your comment in writing!

Randii
 
#23 ·
just to clarify Randy. When does that 45 day period end? Are they only accepting comments that will effect the EIS or will they be required to comment on everything?
 
#24 ·
They tip toed around the 2nd half of your question....I think the intent EIS only....but I don't think they can stop RTMP comments.....maybe Randii has another opinion.
 
#25 ·
atvobsession said:
They tip toed around the 2nd half of your question....I think the intent EIS only....but I don't think they can stop RTMP comments.....maybe Randii has another opinion.
My interpretation agrees with Ken -- their INTENT is to get comments on the RTMP from the 30-day comment, but they soft-shoed around whether they would 'accept' RTMP comments during the EIS draft period.

IMHO, since the RTMP will be part of the EIS, it follows that we can still comment the RTMP during the EIS comment period. Personally, I commented BOTH, to give them the opportunity to implement my comments in good faith, then when I submit them again, I'll get an explanation as to why they included (or not) my comments.

That 45 day period has not started yet -- probably mid-Summer.

Randii
 
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