Ann: VRX Silica Company Update, page-94

It is classic bureaucratic duplicity. VRX have probably addressed all these issues many times over to the different agencies.
I agree, VRX will have addressed these issues at great length and would have been part of the formal submission put together with the assistance of independant consultants.
If you search through the EPA and DMIRS websites, there is a massive amount of information and documentation that has been submitted by VRX.
Even dates and times of phone calls and video meetings are itemised.
I don't think anyone would escape the requirement of an ESD, it seems part of the normal Step 2 process.
The point is , VRX are moving forward.