That is correct. Since the winter Complex Model requires the use of an RVP of 8.7 psi for both baseline and target fuels regardless of the actual RVPs, the valid range limits for RVP do not apply to the winter Complex Model calculation.(7/1/94)
This question and answer was posted at Consolidated List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (PDF)(333 pp, 18.17 MB, EPA420-R-03-009, July 2003, About PDF)