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Advocates said “the VIN requirements should also include a means for encoding the type

of power source that the engine can utilize.”

Yuli Chew, an individual submitting comments, suggested that the seventh digit in the

VIN be used to designate emission certification and offered a detailed chart of proposed

characters to designate various emission certifications. He also proposed that the eighth digit be

used to indicate engine type and similarly offered a detailed chart of engine types and characters

to represent them.

WisDOT asked that the VIN include some method for determining the maximum speed

capability of low-speed motor-driven cycles, such as mopeds. Whether or not a cycle can travel

at speeds greater than 30 mph impacts driver training requirements in Wisconsin and whether

passengers may be carried on the cycle. WisDOT provided a list of 28 other States in which

speed of the cycle determines its classification and related requirements. WisDOT also noted

that the Uniform Vehicle Code contains a similar distinction.

NESCAUM and NACAA recommended that the information communicated by the VIN

include motor vehicle test group and engine family, as defined by the U.S. Environmental

Protection Agency in 40 CFR Part 86. The information that would be available to States as a

result of this, NESCAUM said, “could be used to support air quality monitoring efforts.”

NESCAUM and NACAA also asked for several additional changes to the information a

VIN must communicate. They asked NHTSA to change the definition of “engine type” that now

appears in 49 CFR 565(d). They maintained that the effect of the definition’s second sentence,

which specifically calls for a VIN to represent “the specific make and manufacturer” of an

engine if it powers a “passenger car or multipurpose passenger vehicle, or truck with a gross

vehicle weight rating of 4536 kg. (10,000 lbs.) or less” is to exclude Class 3 through 8 heavy-

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