On paper they are stage 1 referral but it looks like they may have pre-empted things compared to RWD and may not be so far behind as it looks.They possibly had the advantage of knowing what had been asked of RWD. The EPA told MR what they wanted back in 2016 and effectively provided a template. They knew that LD is a controlled action so they have submitted to the Feds straight off.
Ann: UPDATED ENVIRONMENTAL REVIEW DOCUMENT SUBMITTED TO THE EPA, page-6
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