Originally Posted by JamesNoBrakes

Although there is lots of backlog, most of the time when a program is given to the FAA for review, there are multiple errors and issues with it. The FAA is only allowed to accept it if it's "perfect" as far as regulatory requirements and acceptance criteria are concerned. Doesn't mean it has to be a perfect program, but can't have misspellings, page numbers that don't make sense, confusing parts, contradictory parts, must meet regulations, etc. Because this unfortunately does not happen the first time, it becomes a "back and forth" between whomever submitted the program and who reviews it. Now think about all the people in the world (US) that want a program of any kind (not just ATP CTP stuff) or a modification to an existing one, and you can get an idea of the constant pulling in opposite directions that they face. This is why the rule from congress had so much lead time. If one simply didn't believe it was going to happen or thought there'd be an "out" right before the deadline, it's kind of too bad now unfortunately.