The process started considerably earlier than you might imagine. The ludicrous thing is how long the process to authorise these things takes - and yes, that is squarely in the court of the DfT.
Put it this way, the process to start adopting these trains was started in TOC-land nearly 30 months ago - formal lease agreements were only authorised 15 months later and the first train arrived on GWR metals within 4 months of then - 12 months before the final HSTs were due to be withdrawn.
Had there been a cohesive, national, rolling stock strategy (again, see DfT), the 175s might have not been allowed to be parked up and go cold and might just have been ready to enter service before the HSTs were withdrawn. Instead - time, pain and effort is being used to do this retrospectively.