Correct. EPA approval is THE derisk. Everything else doesn't...

Correct. EPA approval is THE derisk. Everything else doesn't matter at all, when there's no approval.
Thinking about this EPA issue a bit longer (which is now going on for roughly four years acc. to the ones here, who have been invested that long), I'm starting to wonder, whether the company knows how to "handle" those people working in authorities. Speaking for myself, I'm working in the regulatory field of a biotech company and have to communicate with "authority people" quite often. They are sometimes a bit special and convincing them of your point of view and your data can be quite challenging sometimes. And you should never argue with them too much. They do have the upper hand and they clearly know that.....