That kind of sounds like the EPA is trying to force Delfin's project into their jurisdiction by issuing a draft they shouldn't even be writing at the moment. Then they can argue for months on end that it needs to be addressed officially before they can accept the new application which will allegedly, possibly render the EPA permit a moot point. You really can't hate these state level ankle biters enough. Little tyrants in training. Or I'm reading it completely wrong and they're lovely people.