Safe harbor is what ended Gore's recounts in Bush v. Gore.
In 2000 The Supreme Court said Gore could have his recount, but they needed to recount all the ballots in a similar method so they remanded back to the State Supreme Court for rules. But even though Gore still had cases and the recount was still technically permissible FL had transmitted their results to the archives and safe harbor kicked in.
Gore didn't so much as lose in court, he ran out of time.
Bush v. Goreas precedent for what SCOTUS would do this time. If they let the Safe Harbor date pass, then this time will be different. That could be because the Rhenquist Court favored Bush, and the Roberts Court doesn't want to be seen as political, or it could be that with 20 years perspective the Court wants to find a way to kick this back to other political actors in the state legislatures and Congress. Declaring that no Safe Harbor will apply to this mess is one way of doing that.