If there are two surveys for RVP/VOC for a covered area per year and both fail, does this result in two "additive" ratchets for the covered area?
No. Failure of surveys during a single year are not "additive", i.e., if any or all surveys in an area are failed during a given year, a single ratchet will be applied for the following year. Additionally, as in Survey Question 6 above, if a refiner is supplying gasoline to many covered areas and several of them experience survey failures, the refinery is subject to the most stringent standard applicable to any of the areas. In 1996, no area could be subjected to more than a single ratchet resulting from a 1995 survey failure.
Thereafter, however, a single area may be subject to two or more consecutive yearly ratchets. In the case of a refiner supplying this area and other areas with standards which have been ratcheted only once, all of the refiner's gasoline would be subject to the most severe ratchet. (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)