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 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)