Nah, I highly doubt that. There has been absolutely no...

Nah, I highly doubt that. There has been absolutely no indication from Bruce through his discussions with the EPA that any further information or work would be required, and he's said this on multiple occasions.
I think this is just a case of, he's intentionally tried to make the previous (12.5c) CR for a relatively low amount, in order to try and minimise dilution and to try and avoid pissing off the longterm holders who were already enraged at being made to wait for as long as they were. He's likely chosen the specific low amount for this previous CR based off of the best estimate of a "worst case scenario" for timelines to achieve EPA signoff, based on the information provided to him by the EPA on their best estimate. Unfortunately, the EPA themselves likely didn't predict the DCCEEW taking several months to reply to an email, and so neither could Bruce. So we're stuck in this sort of limbo, where Bruce is kind of like; "well, shit."
It's unfortunate that the 12.5c CR wasn't for a larger, even more conservative amount of cash, just as it's unfortunate that Bruce couldn't have kept his plant equipment purchasing and spending much lower, just in case something ridiculous like the feds taking months to respond were to occur. But alas.