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intention to remedy this situation but agree that being unable to locate records presents obstacles to effective public participation. Therefore, I will advise the MLRD to formulate a comprehensive policy concerning the maintenance of both types of records, to be implemented statewide. GCA Issue Number 2: I agree that a denial of citizens' rights to submission of additional information regazding the proposed permit after the close of the informal conference and to a timely site visit to view all portions of the proposed operation prior to the informal conference, if such actions occurred, is contrary to Colorado's approved program. However, from the information presented to me concerning the issue of the site visit, it is not possible to determine with certainty the reason that the site visit took place seven days, instead of at least 10 days, prior to the informal conference, nor is it possible to determine what effect an additional three days might have had with respect to GCA preparation for the informal conference. With regard to the new temporary loadout facility located near Rifle, Colorado, it must be noted that right of entry is necessary before an applicant may include it in a site visit. However, recent information indicates that, in conjunction with MLRD's determination that a mine may be permitted without a loadout, this temporary facility at Rifle was specifically excluded from the NCEC permit revision proposed for approval by MLRD on October 19, 1990. Instead, MLRD has directed that NCEC, if it wishes to pursue permitting of this temporary loadout, must submit a sepazate permit revision, in order to allow for adequate public notice and an opportunity for public comment. With reference to the Riverbend property, it does appear, from NCEC's June 7, 1990, letter to the Garfield County Commissioners, that NCEC contemplated using this company-owned location for a permanent loadout facility prior to the June 14, 1990, site visit, but the site has neither been made part of the permit revision for which MLRD proposed approval, nor - to my knowledge -been submitted as a separate permit revision to MLRD. Notwithstanding the incidents associated with the June 14, 1990, site visit to the proposed NCEC operation, the Office of Surface Mining Reclamation and Enforcement (OSM) noted during a recent oversight evaluation of the Colorado program that the State provided administrative reviews in accordance with program procedures, and OSM identified no issues or concerns with MLRD's implementation of its regulations concerning citizen site visits. Thus, overall, I must judge that the denial of citizens' rights to a complete site visit, as asserted by GCA, constitutes an isolated occurrence, the effect of which has been addressed in connection with the processing of the NCEC permit revision. (See the discussion of Re~nse to Request for Institution of a' Federal Program for the NCEC Mine.) With respect to the submission of comments, it must be noted that the conference officer's lack of knowledge concerning the citizens' right to submission of comments following the informal conference, as provided under Colorado's approved program, -- does not invalidate the existence of the regulation guazanteeing this right, nor does it preclude the exercise of the right. The fact that GCA was aware of its right to submit comments is evidenced by GCA representative Welsh's statement to the conference 2