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officer concerning the length of the comment period. Although the conference officer's response may have created some uncertainty regarding submission of post-informal conference comments, the right itself remained intact. Since it is not appropriate nor possible to assess what effect provision of GCA's additional information and comments following the informal conference might have had on the current review of the NCEC revision, my decision must be based upon the fact that GCA did not, for whatever reason, exercise its right to comment. Thus, I am compelled to reject GCA's assertion that the MLRD did not properly implement this portion of the Colorado program. GCA Issue Number 3: This issue concerns MLRD's determination that NCECs application was a "complete permit application," in accordance with 2 CCR 407-2, 1.04(30) and 2 CCR 407-2, 2.07.3(1) which are the respective counterparts to Federal regulations 30 CFR 701.5 (administratively complete application) and 30 CFR 773.13(a), prior to initiation of the public review process. AFO's review of the application materials showed that the requirements of Colorado Rules 2 and 4 were addressed in accordance with the State's definition of a(n administratively) "complete permit application" at 2 CCR 407-2, 1.04{30), with the exception that the permit term information did not indicate that the anticipated life of the mine is 25 years. (The life-of-mine information was, however, contained in the public notice.) According to the information provided by GCA, the State and AFO's September 13, ]990, review of NCEC's application for permit revision, it appears there have been several changes made to the proposed operation concerning right of entry, loadout facilities and method of coal transport since the completeness determination was issued by MLRD on March 19, 1990. It also seems that some of these changes were contemplated or effected after the site visit and the informal conference were held, such as the August 6, 1990, update of application acreage and maps reflecting deletion of the acreage contained in the City of Glenwood Springs parcel, for which NCEC did not have a legal right of entry. (See also discussion of loadout facilities in GCA Issue Number 2.) Further, some of these changes appear to represent significant alterations to the operation as reflected in the permit application revision. While I find it reasonable to believe, and MLRD has stated, that many of the items which relate to the scope of the proposed operation would be dealt with in MLRD's adequacy review, it is also reasonable that changes to the permit which would meet the requirements for significant alterations under the Colorado program would be subjected to additional public review. This, indeed, appears to have been the case with the temporary loadout facility. GCA Issue Number 6: Through means of AFO's examination of MLRD fifes, the lapses of liability insurance and performance bond coverage alleged by GCA could be neither __ confirmed nor denied. _Since current MLRD files were found to contain appropriate certification of insurance and bond documents, this issue need not be further addressed. 3 yJ