<I can't imagine, why the TPL attorneys waited so long to do that response, if it was truly needed prior to the NIRC review. >

Excellent point. Quite possible that it was a loose end that just needed doing for the NIRC to proceed. The copy submitted with the request for extension of time may not have covered the requirement. It certainly sounded like it was required in that there was a specified time period to submit and no extension of time was required. Yes, that could be read as very positive.

Opty