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(WDE), General Motors (GM), Ford, Harley-Davidson Motor Company, BMW of North

America, The Northeast States for Coordinated Air Use Management (NESCAUM), the

Association of International Automobile Manufacturers (AIAM), the Truck Manufacturers

Association (TMA), the National Association of Clean Air Agencies (NACAA), Ferrari, Prevost

(a division of Volvo Group Canada, Inc.), the National Association of Trailer Manufacturers

(NATM), and several individuals.

1. General and Issue Specific Support

All commenters supported revising the VIN regulation in one way or another, in some

instances suggesting ways the VIN could be further expanded.

Amendments Aimed at Extending Life of Current System

The Alliance stated that it “fully supports both proposed amendments that are directly

related to extending the utility of the VIN system beyond 2010.” AIAM and TMA also

expressed support for the proposed changes, as did Ferrari and NATM with some exceptions and

concerns. NYDEC offered its general support for the efforts “to ensure that there will be a

sufficient number of unique manufacturer identifiers and VINs for the current 17-character VIN

system for at least another 30 years.” Harley-Davidson also offered its “general support,”

noting, “The regulatory proposal as written will provide a solution to the issue for the next few

decades.” BMW supported NHTSA’s efforts to revise Part 565, but had concerns, as did

Daimler A.G., about the proposed changes for position 7 of the VIN. NICB offered its support,

but expressed concern that the effective date should be November 1, 2008.

NESCAUM, which is an association of state air pollution control agencies in

Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and

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