Just anecdotally in talking with companies and from my own experience, the discussion that goes on within these companies is whether or not it is worth embarking on a two- or three-year project for upgrades. Because of the time, amount, and the human resources required to move something through the CEAA process, companies often say that they decided not to do something because it just wasn't worth entering the approvals process. Time and money are important. So they just move on or leave things until they absolutely have to change something, and it becomes precipitous.
It's the same with gaming. The discussions go on. It's a screening, they'll say, but it might be better to have a comprehensive study, because at least the timelines are somewhat predictable. The problem with the screening is that there are no predictable timelines. So they try to move projects around. The gaming has to do with whether they can move it to an area where there are no triggers. As a result, they get suboptimal projects, or not the project they envisioned originally, and all because they don't want to enter the whole process.