Ann: Quarterly Activities Report and Appendix 5B Mar 2023, page-10

it is highly unlikely that IP is thinking "yeah i'll get around to the ERD soon but for now i'll just cruise"

it is more like..

IP..Hey EPA tell me exactly what you need and we will submit it

EPA..ummm we need x y and z completed then we may need some additional info depending on who looks at your submission

IP...No tell what you need NOW and we will provide it

EPA..ummm we will get back to you on the specifics once we view your EPD


and on and on it goes...