Given that the number of surveys required in later years (after 1995) will, in part, be determined by survey failures, when will EPA announce the adjusted number of required surveys for 1996 (or subsequent years)? How can a survey plan be submitted by September 1, 1995, if the adjusted number of surveys for 1996 is not known?
The survey plan will have to take into account whatever contingencies may occur. Any change in the total number of surveys which may be triggered by areas "passing" or "failing" surveys (see section 80.68(b)(2)(ii)) will not result in any change in the actual areas covered by the surveys. Rather, it will only change the number of surveys required for those areas. Thus, the survey plan will still have to address information such as how representative samples will be identified in each city and all other site-specific factors in planning a survey. In terms of total numbers of surveys, the plan should address the "worst case" contingency of no drop in total surveys required. If the total number of surveys drop, any plan which addresses the "worst case" contingency should accommodate a smaller number of total surveys.
For new opt-in areas, the Administrator has some discretion in setting the date for compliance with introduction of RFG. Utilizing this discretion, and working with the states on scheduling opt-in requests, the Agency will work to facilitate opt-in schedules so as to not disrupt the efficient planning of surveys or introduction of RFG generally.(7/1/94)
This question and answer was posted at List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)