Among the FY2027 tax reform requests submitted at the end of August 2026 by the Cabinet Office (Okinawa Policy), one item—filed jointly with the Ministry of Economy, Trade and Industry (METI) and the Ministry of Land, Infrastructure, Transport and Tourism (MLIT)—asks to extend the special tax measures for “Tourism Area Formation Promotion Zones” (観光地形成促進地域) under the Act on Special Measures for the Promotion and Development of Okinawa (an investment tax credit plus local tax exemptions) by three years, pushing the current March 31, 2027 sunset to March 31, 2030. The only request filed under the Japan Tourism Agency’s (JTA) own name was a single item: revising the tax-free sales verification procedures in light of the introduction of the electronic travel authorization system (JESTA). The Okinawa scheme runs through the Cabinet Office’s Okinawa development framework, not the JTA. This article goes back to the original request documents and Okinawa Prefecture’s program guide to clarify what the extension request means for lodging operators—namely, that guest-room buildings themselves are excluded and the measure applies only to ancillary facilities such as hot-spring health facilities and conference facilities. We then quantify the IRR impact with a simplified 100-room resort model and lay out Okinawa’s room stock, 2026 openings, and a backward-planning timeline to the ruling coalition’s tax reform outline in December.

The content of this article reflects ministries’ “requests” as of August 2026, not final decisions. Whether and on what terms the extension is granted will be determined by the ruling coalition’s tax reform outline in December 2026 and the legislative amendments the following year.

Reading the Request Documents in the Original — Not a “JTA Request” but the Cabinet Office’s Okinawa Development Framework

First, let us pin down where the primary sources are. Of the FY2027 tax reform requests published together by the Ministry of Finance in September 2026, the only request filed in the name of the Japan Tourism Agency (Tourism Strategy Division) is No. 26-1, “Review of verification procedures for the consumption tax exemption system for foreign travelers in connection with the introduction of the electronic travel authorization system (JESTA),” covering consumption tax and liquor tax, with the period of application listed as a “permanent measure.” The extension of the Tourism Area Formation Promotion Zone measures, by contrast, appears in request No. 07, “Extension of special tax measures in Okinawa’s Tourism Area Formation Promotion Zones” (tax item: corporate tax), filed by the Office of the Counsellor for Planning under the Director General for Policy on Okinawa, Cabinet Office, as “a joint request with METI and MLIT.” On the local tax side, items of the same name appear as No. 45 (METI) and No. 54 (MLIT) in the local tax reform requests published by the Ministry of Internal Affairs and Communications. MLIT’s own list of requests also places it in the “under the jurisdiction of other ministries” column. In other words, this is not part of the JTA’s policy framework but a scheme operating under the Okinawa development framework based on Articles 8 and 9 of the Act on Special Measures for the Promotion and Development of Okinawa, and it must not be confused with measures that apply to lodging facilities nationwide. The full set of FY2027 request items available to lodging operators across Japan is summarized, together with their effect per 100 rooms, in Japan FY2027 Tax Requests: 15 Hotel Breaks.

The substance of the request is as follows. For the special tax measures in the Tourism Area Formation Promotion Zones under the Okinawa act, the sunset date (March 31, 2027) would be extended by three years to March 31, 2030. The measure is an investment tax credit: when the acquisition cost of equipment for new construction or expansion of eligible facilities exceeds ¥10 million, 15% of the acquisition cost of machinery and equipment and 8% of the acquisition cost of buildings, building fixtures and structures can be credited against corporate tax (capped at 20% of corporate tax liability, 4-year carryforward, acquisition cost capped at ¥2 billion). Building fixtures qualify only if acquired at the same time as the building. If the corporate tax extension is approved, it automatically flows through to the corporate inhabitant tax (corporate tax levy), and in Naha City the measure halving the tax base for the asset-based portion of the business office tax for five years for specified private tourism-related facilities with buildings etc. exceeding ¥100 million would also continue. The Cabinet Office’s summary document adds the exemptions from enterprise tax, real estate acquisition tax and fixed asset tax, and frames the request as “extending the current measures by three years.”

Source: Ministry of Finance, “FY2027 Tax Reform Request Items” (Cabinet Office No. 07; MLIT/JTA No. 26); Ministry of Internal Affairs and Communications, “FY2027 Local Tax Reform Request Items” No. 45 and No. 54; Okinawa Prefecture, “Guide to the Tourism Area Formation Promotion Zone Program” (August 2025). Compiled by HotelBank Editorial Team

The request document also states targets and track record. For each of FY2027–FY2029, the Cabinet Office expects “capital expenditure on specified private tourism-related facilities by businesses using this measure of approx. ¥3.1 billion” and “an increase in value added of approx. ¥830 million,” tying these to a target of ¥1.3328 trillion in Okinawa tourism revenue in FY2029. Usage, according to the Ministry of Finance’s survey on the application of special tax measures, was small: 2 cases and ¥18 million in FY2022, 0 cases in FY2023, and 2 cases and ¥13 million in FY2024. In FY2025 it jumped to 11 cases and ¥4,149 million, based on an estimate from application information at the time of competent minister confirmation. Cumulative capital expenditure by FY2025 users came to ¥51,862 million, and the request document itself notes that “exceptionally large investment projects” were excluded from the normal-year projection. FY2026 stood at 2 cases and ¥532 million as of June 12. With the number of cases in single digits throughout, this is a scheme whose case for extension hinges on how far a small number of large projects make use of the tax credit.

Guest-Room Buildings Are Excluded — The Scheme Only Reaches “Ancillary Hot-Spring Health Facilities and Conference Facilities”

This is the point this article most wants to establish. Okinawa Prefecture’s guide states explicitly that “lodging facilities themselves do not qualify as specified private tourism-related facilities and are not eligible for the special tax measures under either national or local taxes.” The eligible specified private tourism-related facilities fall into five categories: (1) sports and recreation facilities (swimming facilities, skating rinks, training centers, golf courses, theme parks, bowling alleys); (2) educational and cultural facilities (theaters, zoos, botanical gardens, aquariums, cultural introduction and experience facilities); (3) recreational facilities (observation facilities, hot-spring health facilities, spa facilities); (4) assembly facilities (conference facilities, training facilities, exhibition facilities, wedding venues); and (5) retail facilities designated by the governor. Of these, the ones that can qualify for the national investment tax credit when attached to a lodging facility are limited to hot-spring health facilities, conference facilities, training facilities and wedding venues. Since wedding venues located in the same building as the lodging facility are excluded, the practical battleground is hot-spring health facilities and conference/training facilities.

In addition, the national tax credit requires that “the facility’s usage rules make clear that, apart from usage fees, general users may use the facility on the same terms as lodging guests, and that this information is easily accessible via the internet or other means.” Conference facilities must have two or more meeting rooms with at least as many audiovisual systems, with each meeting room structurally separated (partition dividers do not qualify) and not convertible into guest rooms. Hot-spring health facilities must include hot-spring baths, a health consultation room (staffed by a physician, public health nurse or nurse) and a rest area, and must be structurally separated from guest rooms etc. (excluding common areas) and not easily convertible. In terms of eligible assets, portions relating to offices, dormitories or lodging facilities, parking facilities, restaurants and retail facilities are also excluded. The local tax exemptions do not impose the national-tax requirement of opening the facility to general users on the same terms, but the scope of eligible facilities is the same, and the real estate acquisition tax exemption is limited to “buildings used directly for the eligible facility” and the portion of land on which construction begins within one year of the day following acquisition.

Source: Okinawa Prefecture, “Guide to the Tourism Area Formation Promotion Zone Program” (August 2025), pp. 2–10; Cabinet Office, “FY2027 Tax Reform Request Item 07.” Compiled by HotelBank Editorial Team

For contrast, the same Cabinet Office requests include a separate item, “Extension of special tax measures for the ryokan/hotel business on Okinawa’s remote islands” (request No. 02, income tax and corporate tax). Based on Article 88 of the Okinawa act, this allows 8% special depreciation when buildings used for the lodging business and their fixtures on remote islands are newly built, expanded or renovated—so the guest-room building itself is eligible. The minimum acquisition cost varies by capital size: for individuals or companies with capital of ¥10 million or less, ¥5 million or more for new construction, expansion or renovation; for capital over ¥10 million up to ¥50 million, ¥10 million or more for new construction or expansion; and for capital over ¥50 million, ¥20 million or more. A 3-year extension is requested for this measure as well, and for operators building guest-room buildings on remote islands such as Ishigaki City and Miyakojima City, it is more directly relevant than the Tourism Area Formation Promotion Zone measures. Note, however, that special depreciation defers tax rather than exempting it—a point we verify in the model below. For bonus depreciation and fixed asset tax exemptions in depopulated, remote-island and peninsula areas beyond Okinawa, Japan Hotel Tax Breaks: 48% Bonus Depreciation Moves IRR by 0.6pt estimates the IRR impact using the same 100-room model.

Simplified 100-Room Resort Model — How Many Points Do the Tax Credit and Local Tax Exemptions Move IRR?

So how much would lodging investment returns move if the scheme were extended? We test this with a simplified model with explicit assumptions. The case assumes a newly built 100-room upper-midscale resort in a resort location on the main island of Okinawa, with a hot-spring health facility (spa) and conference facilities developed at the same time as ancillary facilities. Construction cost uses the 2025 steel-frame cost of ¥2.405 million per tsubo from MLIT’s Building Construction Starts statistics; with a gross floor area of 8,000㎡ (about 2,420 tsubo), the building costs ¥5.82 billion, plus land of ¥700 million and FF&E of ¥300 million, for total investment of ¥6.82 billion. For ADR, given that the estimated settled ADR of Okinawa resort hotels was ¥22,300 in August 2026 (median, N=282 properties), we set ¥45,000 as the level for a new upper-midscale property. For occupancy, we set 70%, since the JTA’s Overnight Travel Statistics Survey (2025 final figures) puts Okinawa resort hotel occupancy at 66.6% (3rd nationwide).

Source: Prepared by MetroEngines Research & Consulting. This is a simplified estimate; actual investment decisions require a detailed feasibility study

The tax measures were incorporated as follows. The investment tax credit of 8% of the acquisition cost of buildings and building fixtures for eligible facilities is used up through year 5 (4-year carryforward), capped at 20% of each year’s corporate tax, and also flows through to the corporate tax levy of the corporate inhabitant tax. Real estate acquisition tax on the eligible facilities’ building portion is exempted; fixed asset tax on the eligible facilities’ building portion is exempted for five fiscal years; and enterprise tax, which is apportioned by employees directly engaged in the eligible facilities, is exempted for five years with a cap of ¥3 million per year. As a result, against a base case (no measures) after-tax IRR of 5.72%, Case A (ancillary facilities at 5% of the building = ¥291 million) yields 5.81%, +0.09pt; Case B (15% = ¥873 million) yields 5.91%, +0.19pt; and Case C (30% = ¥1,746 million) yields 5.99%, +0.27pt. The tax credit amounts to ¥23 million in Case A, ¥70 million in Case B and ¥140 million in Case C.

Source: MetroEngines Research & Consulting (simplified estimate)

There are two takeaways. First, the effect is determined by the size of the ancillary facilities, not total investment. Whether a property has 100 or 200 rooms, if the acquisition cost allocated to the hot-spring health facility and conference facilities is the same, the credit is the same, and for projects with a base IRR in the 5% range the uplift falls within +0.1 to +0.3pt. Because conference facilities must be designed with two or more structurally separated meeting rooms that cannot be converted into guest rooms, resorts targeting MICE demand and spa-equipped properties involving hot-spring drilling will have a thicker base of eligible assets and move closer to Cases B–C. Second, although the remote-island lodging special depreciation covers “the entire guest-room building,” its IRR uplift is only +0.04pt. Special depreciation is a deferral that shifts the first-year tax burden to later years, so the total tax over 10 years is unchanged. Thickening early cash flow matters for debt service, but the measure does not raise the level of returns itself. Even a remote-island project combining both measures gains only +0.22pt.

Accordingly, if the extension request is approved, what changes is less the “invest or not” decision than the practical work of “how to design the ancillary facilities, and how to schedule governor certification and competent minister confirmation before acquisition.” Competent minister confirmation is applied for with targets for an increase in value added plus either maintaining the number of regular employees and increasing total wages, or increasing the number of regular employees, and obtaining certification and confirmation before acquiring the assets is an absolute requirement.

Room Stock in the Eligible Area — Distribution of Okinawa’s 42,577 Rooms and the Estimated Settled ADR Hierarchy

The scheme’s eligible area is all of Okinawa Prefecture (41 municipalities). Within the scope tracked by MetroEngines Research, there are 1,474 properties and 42,577 rooms in Okinawa confirmed as operating on OTAs (hotel master tally as of October 2026), of which 118 properties and 25,871 rooms—61% of rooms—are in properties with 100+ rooms. By municipality, Naha City accounts for 227 properties and 16,614 rooms, or 39% of the total, followed by Onna Village with 4,830 rooms, Ishigaki City 4,803, Miyakojima City 3,161, Nago City 2,390 and Chatan Town 2,051. By category, resort hotels (201 properties, 18,643 rooms) and business hotels (180 properties, 14,178 rooms) are the two pillars, while city hotels are few at 8 properties and 1,748 rooms. For the property-level distribution of large hotels, Okinawa Hotel Room Count Ranking 2026 organizes the 34 properties with over 300 rooms by region.

Source: MetroEngines Research & Consulting (OTA-listed basis, as of October 2026)

Looking at the price hierarchy through estimated settled ADR, the median for Okinawa resort hotels was ¥22,300 in August 2026 (N=282 properties), +3.1% YoY, and ¥16,800 in September, +7.3% YoY—holding above the prior year even past the summer peak. The all-property median was ¥14,700 in August (+2.7%) and ¥12,000 in September (+10.0%); business hotels were ¥9,700 in August (+3.3%) and ¥8,800 in September (+9.4%). By municipality, Onna Village stood at ¥33,000 in August (N=43), Chatan Town ¥19,500 (N=24), Miyakojima City ¥18,800 (N=76), Ishigaki City ¥16,100 (N=60) and Naha City ¥10,200 (N=143)—a threefold gap between resort locations and urban Naha. The model above assumed an ADR of ¥45,000 because it targets a new upper-midscale tier positioned above these medians; the same model also shows that at an ADR below Onna Village’s resort median, returns on a new build’s ¥6.8 billion total investment are hard to justify.

2026 Openings and Planned Projects — Net Additions Excluding Rebrands: 7 Properties, 1,428 Rooms at 100+ Rooms

Within the scope tracked by MetroEngines Research, 97 properties and 2,935 rooms were registered as opening in Okinawa in 2026 (OTA-listing basis). The breakdown, however, shows that 69 of these are small properties of 1–9 rooms, such as 52 vacation rentals (83 rooms) and 6 cottages (14 rooms); meaningful supply is concentrated in 10 properties with 100+ rooms totaling 2,316 rooms. Of those 10, three properties with 884 rooms are rebrands of existing properties rather than genuine new-build supply: INFINISIS Naha Shurijo by Hewitt Resort (インフィニシス 那覇 首里城 by ヒューイットリゾート; 328 rooms, began operating on July 31, 2026 after rebranding an existing property), The Grand Castle Naha Shurijo by Hewitt Resort (ザ グランドキャッスル 那覇 首里城 by ヒューイットリゾート; 333 rooms, inheriting the name of an existing hotel opened in 1973, scheduled to begin operating on January 1, 2027), and Hotel Monterey La Soeur Naha (ホテルモントレ ラ・スール那覇; 223 rooms, rebrand opening on April 3, 2026). Excluding these, new builds of 100+ rooms total 7 properties and 1,428 rooms, equivalent to about a 5.5% addition to Okinawa’s 25,871-room stock of 100+ room properties.

Source: MetroEngines Research & Consulting (OTA-listing basis; 7 new-build properties with 100+ rooms out of N=97 properties). The room count for Canopy by Hilton Okinawa Miyakojima Resort uses the 306 rooms stated in Hilton’s “Company Overview” (updated August 25, 2026)

Some individual notes: The Royal Park Hotel Iconic Naha (257 rooms) opened on January 30, 2026 on the upper floors of the Bank of the Ryukyus’ new head office building; RIHGA Royal Resort Okinawa Chatan (209 rooms) opened on April 1; Southgate Hotel Okinawa (216 rooms) opened on May 23 in the terminal building at Tomari Port, Naha; and PGM Hotel Resort Okinawa (201 rooms) opened in Onna Village on July 3. Canopy by Hilton Okinawa Miyakojima Resort opened on April 1, 2026; according to Hilton, it operates 37 hotels under 9 brands in Japan, and together with the adjacent Hilton Okinawa Miyakojima Resort (329 rooms, opened 2023) it now has two properties on Miyakojima (Source: Hilton Company Overview, updated August 25, 2026). In Kise, Nago City, Courtyard by Marriott Okinawa Resort (コートヤード・バイ・マリオット沖縄リゾート; 170 rooms) opened on June 15, 2026, but as a rebrand of the former Kanehide Kise Beach Palace (かねひで喜瀬ビーチパレス) rather than new-build supply, it is not included in the table above.

As for planned projects, MLIT’s Building Dynamics Statistics Survey (building confirmation application basis) lists only one hotel-use project in Okinawa: in Nishihara 6-chome, Urasoe City (200 rooms, 17 floors above ground, gross floor area 20,700㎡, construction started April 2023, scheduled completion July 2026, owner: Plenty Co., Ltd. (株式会社プレンティー)). *This is based on confirmation applications at the time of the survey; the number of projects and rooms is expected to increase as further applications are filed, so it should be treated as a lower bound of the currently confirmed pipeline. Openings on an OTA-listing basis will likewise rise for the remaining months of 2026 and for 2027 as listings appear, since listings go up several months before opening.

Okinawa’s Investor Base Through REIT Holdings — 13 Properties, 3,204 Rooms, ¥170.3 Billion in Acquisition Prices

Among Okinawa’s lodging facilities, properties owned by seven listed hotel REITs—Ichigo Hotel REIT Investment Corporation (いちごホテルリート投資法人, 3463), Invincible Investment Corporation (インヴィンシブル投資法人, 8963), Nippon Hotel & Residential Investment Corporation (日本ホテル＆レジデンシャル投資法人, 3472), Japan Hotel REIT Investment Corporation (ジャパン・ホテル・リート投資法人, 8985), Hoshino Resorts REIT (星野リゾート・リート投資法人, 3287), Mori Trust REIT (森トラストリート投資法人, 8961) and Kasumigaseki Hotel REIT (霞ヶ関ホテルリート投資法人, 401A)—total 13 properties and 3,204 rooms in our ownership master (as of October 12, 2026), with aggregate acquisition prices of ¥170,311 million. The largest is Invincible’s Fusaki Beach Resort Hotel & Villas (フサキビーチリゾートホテル＆ヴィラズ; Ishigaki City, 398 rooms, acquisition price ¥40,293 million, acquired August 2023), while JHR holds 5 properties with 1,818 rooms in Naha City, Yomitan Village, Nago City and Itoman City. In 2025, Ichigo Hotel REIT acquired Smile Hotel Miyakojima (スマイルホテル宮古島; 135 rooms, ¥2,300 million, July 2025) and Kasumigaseki Hotel REIT acquired seven x seven Ishigaki (121 rooms, ¥18,700 million, August 2025), showing that remote-island resorts are actively being acquired.

Source: Compiled by MetroEngines Research & Consulting from each REIT’s portfolio list and property summaries (ownership master as of October 12, 2026, N=13 properties). Properties of Japan Hotel REIT Investment Corporation and Hoshino Resorts REIT are shown as “—” because their portfolio lists do not publish property-level acquisition dates in a verifiable form

Dividing acquisition price by room count, Fusaki Beach Resort comes to about ¥100 million per room, seven x seven Ishigaki about ¥150 million, Okinawa Harborview Hotel about ¥61 million and Mercure Okinawa Naha about ¥12 million—a more than tenfold range in per-room price within the same prefecture. The 100-room, ¥6.8 billion total investment in the model above works out to ¥68 million per room, within the band of resort properties REITs have acquired. The Tourism Area Formation Promotion Zone measures do not apply to acquisitions of such existing properties (new construction and expansion are eligible); they apply to renovation investment involving expansion or new ancillary facilities. When a REIT asset manager considers adding a spa or conference facilities, there is room to bring the investment within the tax credit if the acquired assets meet the structural separation requirement and the rules on opening to general users.

The Tax-Free System and JESTA — Where It Affects Hotel Shops and Check-In Operations

The JESTA-related item, the only request in the JTA’s name, matters to lodging facilities in the practicalities of running in-house shops. The amended Immigration Control Act (Act No. 32 of 2026) provides for the introduction of the electronic travel authorization system (JESTA) during FY2028, after which the landing permission stamp in passports will be omitted for some short-term visitors. Because tax-free shops currently verify eligibility for tax-free purchases mainly by the landing permission stamp, the JTA, METI and the Ministry of Justice are asking to “conduct the necessary review of verification procedures for tax-free sales at tax-free shops and take the required measures.” The request does not specify a verification method, and the system design is being considered as a permanent measure.

Before that, hotel shops with a tax-free license must adapt to the refund system that starts with purchases made on or after November 1, 2026. According to the JTA, tax-free shops will sell at tax-inclusive prices and transmit purchase records to the National Tax Agency’s tax-free sales management system, and travelers will receive a refund of the consumption tax amount after undergoing customs verification at the airport or seaport upon departure within 90 days of purchase. There is no transition period running alongside the current system; all sales from November onward will be under the new system. The stamp omission under JESTA would further alter the identity verification flow of this new system, and will affect operational design from FY2027 onward, including whether to keep the shop’s tax-free license. As for Okinawa-specific tax-free programs, the Cabinet Office is also requesting a 5-year extension of the “Okinawa specified tax-free shop system,” which allows passengers departing Okinawa for other prefectures to make customs-duty-free purchases up to ¥200,000. It covers the specified retail facility in Omoromachi, Naha City (positioned as a retail facility within the Tourism Area Formation Promotion Zone) and shops inside Naha Airport. It does not directly affect hotel retail operations, but it is worth noting, as a matter of how the scheme was built, that the “retail facility” category of the Tourism Area Formation Promotion Zones is tied to Okinawa’s tax-free shops.

Backward-Planning Timeline — From the August Requests to the December Outline and Enforcement in April 2027

The process leading to the final tax reform follows a largely fixed annual schedule. For FY2026 (the previous cycle), the ruling coalition’s tax reform outline was decided on December 19, 2025 and approved by the Cabinet on December 26. Assuming FY2027 follows the same timeline, what each business can prepare now can be organized as in the table below.

Source: Ministry of Finance, “Overview of Tax Reform”; Liberal Democratic Party, “FY2026 Ruling Coalition Tax Reform Outline” (December 19, 2025); Okinawa Prefecture, “Guide to the Tourism Area Formation Promotion Zone Program.” Compiled by HotelBank Editorial Team

Note that the current scheme covers assets “placed in service by March 31, 2027.” Projects placed in service from April 2027 onward cannot receive the measures unless the extension is approved. Conversely, projects that include ancillary facilities completed in FY2027 may still be in time for the law’s enforcement even if they wait for the December outline before applying for governor certification—but since certification and confirmation are required before acquisition, meeting the requirements at the design stage is a prerequisite. Also, while the request is for three years, a past revision settled on a 2-year extension (from March 31, 2025 to March 31, 2027), so the extension period may not end up as requested.

Summary — How to Factor In a Scheme That Is Still at the Request Stage

Among the FY2027 tax reform requests, Okinawa’s Tourism Area Formation Promotion Zone investment tax credit and local tax exemptions are at the stage where the Cabinet Office, jointly with METI and MLIT, has requested a 3-year extension. Whether it is extended, for how long and on what requirements will be decided by the ruling coalition’s tax reform outline in December 2026 and the 2027 legislative amendments. The content of this article is not a final decision. What we could confirm about the scheme’s contours is that guest-room buildings themselves are excluded and the measures apply only to ancillary hot-spring health facilities, conference facilities and training facilities (and wedding venues in separate buildings); that the national tax credit requires opening facilities to general users on the same terms; that it operates within a framework of acquisition cost over ¥10 million, a ¥2 billion cap and a limit of 20% of corporate tax; and that certification and confirmation must be obtained before acquiring the assets.

In the simplified 100-room resort model, the IRR uplift from the measures falls in the +0.1 to +0.3pt range depending on the scale of ancillary facilities—not large enough to swing an investment decision, but the effect grows for projects with substantial MICE functions or spas. The eligible area of Okinawa has a room stock of 42,577 rooms, and in 2026, excluding rebrands, 7 new-build properties with 100+ rooms added 1,428 rooms. Estimated settled ADR is firm, with the resort hotel median at ¥22,300 in August (+3.1% YoY), and REITs acquired two properties on remote islands in 2025. If the extension is approved, projects with ancillary facilities completed in FY2027 or later will fall within the measures’ scope. What businesses can do while awaiting the outline is to put the design requirements and certification steps in order; it would be realistic to plan for multiple acquisition timings, including the possibility that the extension is shortened to two years or that requirements are revised.

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