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With no set procedure for declaring per gallon/averaging, it appears a refinery has until the first quarterly report to make a decision. As long as per-gallon standards were met up to the point the first quarterly report is filed, and the refiner meets the gasoline quality survey requirements, the option would remain open to go averaging for the year. Is this acceptable?

See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help.

It is true that EPA did not include in the RFG rule a process for regulated parties to notify EPA in advance of per-gallon versus averaging. As a result, the strategy described in the question would be appropriate. (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) (2.98 MB, July 2003)