There may be a contrary answer to the Berlin situation. Today Tesla is battery constrained. it is still not clear where the Berlin packs will come from. Every battery cell Tesla makes is sold. Until very very recently it was not clear, to me, how Berlin was going to operate at any scale because the battery pack for that site is very specific. At least as far as I understand, that pure 4680s. Now maybe Tesla has finally cracked that problem but until early this winter we still don't have enough packs to even launch a rudimentary Semi line. Opening Berlin without have battery capacity would be unhelpful in the extreme, from strategy to competing OEM espionage/intelligence efforts, etc. Thus no real need to rush paperwork and have an approval and twiddle thumbs.
It would explain why Tesla took forever to submit basic paperwork. Assuming it is the govt agencies in Germany might be missing the more obvious answer...that it is Tesla battery constraints. It seems to me that Tesla might not have been ready to really scale and that would imply that battery challenges remain. Clearly Tesla not submitting paperwork until December is not a mistake. That's PM 101.