My thoughts ..... It's not like they were not aware of the fast approaching time limitation... If I recall, they have been sitting on your proposal for a month or so... I think the threat to file has had the desired effect, ie, they are actually doing something.
As for costs, what costs? ..... If you file, they respond with their proposed consent orders which they say they are going to do anyway. At least if you have filed, it will remain so until you have actual orders.
As for costs, what costs? ..... If you file, they respond with their proposed consent orders which they say they are going to do anyway. At least if you have filed, it will remain so until you have actual orders.