There are exceptions for unanticipated delays that may enable a project to extend beyond 31 months. However, the initial deployment plan must plan to deploy all the assets within 31 months and any extension, generally, needs to relate to governmental delays that were unanticipated. For example, if the plan anticipates re-zoning approval within six months but the respective zoning board delays the hearing or a decision beyond the six-month period, the project may be entitled to an extension of the 31-month period equal to the time beyond the six-month period originally anticipated. However, it is unlikely you can "game" the system by setting unrealistic timelines for governmental actions. If it normally takes six months to get rezoning approval, your plan can't anticipate two months to obtain rezoning approval so that the original 31 months can be extended to 35 months.