Where is it required in the regulations that the PTD's for RFG must designate the finished gasoline as meeting the oxygenate standard on the per-gallon or average? Would it not be sufficient to infer the average standards from the listings of min/max's on the PTD? This requirement is not found in § 80.77.
The PTD requirements for RFG do not require that gasoline be designated as meeting the standards, including the oxygenate standard, per-gallon or average. Section 80.77 does require that PTD information include the minimum and maximum downstream standards with which the RFG complies.
The downstream standards are the same regardless of whether the RFG has been certified as meeting standards per-gallon or on average. The downstream minimum/maximum standards must be included in the PTD information because these standards are subject to change with regard to specific covered areas in the event of a standard "rachet" as a result of a gasoline quality survey failure under § 80.68. (10/17/94)
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)