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The Alliance and AIAM supported moving vehicle “make” from the manufacturer

identifier to the second section (positions 4-8) of the VIN. On the other hand, NATM believed

that there is no need to assign or designate the “make” of a trailer.

Vehicle Characteristics for VINs of Low Speed Vehicles (LSVs)

Advocates supported the proposal to include in Part 565 a list of vehicle attributes that

must be communicated in, and decipherable from, the VINs of LSVs.

Costs Resulting From Software Modifications

NICB said its software can be modified to accommodate the proposed changes “without

undue burden or expense.”

2. Suggested Changes to the Information to be Communicated by the VIN

Comments:

Several commenters suggested adding various kinds of information to what is currently

required in 49 CFR Part 565 to be communicated in, and decipherable from, a VIN.

ODMV, ODEQ, WDE, NESCAUM, and NACAA all urged NHTSA to incorporate into

the VIN a means by which States could determine whether or not a vehicle is certified to meet

California emission standards. NYDEC urged a more detailed approach, asking for not only an

indication of the emission standard to which a vehicle is certified, but also the level of

certification.

NYDEC and NYDMV also suggested that a vehicle’s fuel type or type of hybrid

technology be communicated through the VIN to help support State inspection and maintenance

programs. In some cases, information that is already included in the VIN and that relates to the

administration of State inspection and maintenance programs, is not treated consistently by

manufacturers and is, therefore, hard to access, according to NYDEC.

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