The thing is, exactly what you describe already exists. Here it is
The problem is that the timeline of updates and events don't align to the documented EPA process.
For example, on the 24th of May 2021 the Chair already determined that this proposal requires assessment S39(a). This means we effectively CLEARED stage 2.
In the Chair's stage 2 determination it is also noted very clearly that the proponent (VRX) has already prepared the ESD. This is back in MAY '21.
It is also noted that the proposal will require 4 weeks public review of the ERD.
The documented process states that the ESD is reviewed in STAGE 3 and then if necessary an ERD (for public review) needs to be compiled by VRX.
We appear to be stuck, or rather, the EPA appears to be stuck at Stage 3 step 2. Since we have already submitted the ESD and we are aware that a public review is necessary. All of the hold ups must be caused by the EPA not knowing what is required or how to progress our proposal to the official public review period.
I have circled the point in the process where we have stalled.
