I would argue that they are steps in a multi-stepped process and until you've climbed all of the steps, you don't get the prize. I don't think any passive acceptance would be construed as governmental action in any regard.
That being said, I've had a quick glance at 1257 and I think acceptance of the EIS might make for a good argument. Keep in mind, I have ABSOLUTELY no knowledge of VE law, my statements are purely and humbly in my own opinion. Each should do their own DD.
Here is a rough translation of Decree 1257, Article 40 which KRY says doesn't apply to them... Not so sure...:
Article 40 .- In the event of changes in the programs or projects subject to an Environmental Impact Study, those responsible for them should make an Environmental Impact Study, an environmental assessment or additional Specific to prevent, mitigate and correct the effects environmental not considered originally. The Ministry of Environment and Renewable Natural Resources determine the origin of the assessment or study, according to the scope and complexity of
potential impacts of the proposed amendments.
