However, saying that something must be done by that date makes that a deadline, not a.... It doesn't say “on December 31” or “not before December 31”. I read that as saying that it could be any time up to and including December 31, 2029. I'd like to be convinced otherwise, but that's my reading. Saying that I have to submit an assignment by January 1 means that I can submit it anytime between now and then.
I assume that by using that language—“by” that date—allows the government to do it faster, which is our concern about BQ-5 on its own.
I'm not convinced that this actually achieves what Mr. Bachrach and Mr. MacGregor are hoping it does. It doesn't provide that certainty, because it seems to me to be a deadline. It doesn't seem to be preventing it from happening much more quickly than has been anticipated.
We need an answer to that before we can decide how to proceed here. I look for guidance, because it seems to me that this is a deadline, not a “not before” type of situation.