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positions 4 through 8, the positions referred to in Part 565 as the second section, which includes

position 7.)

The Alliance and GM both specifically supported the proposed change from numeric to

alphabetic characters in position 7. In addition, the Alliance asked that a footnote be included in

Table VII – Year Codes for VIN in 49 CFR Part 565. That footnote would read, “If position 7 is

numeric, the Model Year (in position 10) is 1980-2009; if alphabetic, the Model Year (in

Position 10) is 2010-2039.” AIAM and Ferrari supported this proposal.

Prevost suggested the addition of a footnote to Table VII as well. It asked that the

footnote communicate the fact that since position 7 may be alphabetic or numeric for vehicles

over 10,000 pounds and certain other types of vehicles covered by Part 565, such as trailers, that

character does not indicate the 30-year period in which the vehicle was manufactured.

Agency Analysis and Response:

The reason for the proposed change in position 7 of the VIN was not only to create

additional permutations to increase the number of available VINs, but also to enable VIN users

to determine in which 30-year period a vehicle was manufactured. The suggestion by Daimler

and BMW that manufacturers have the option of using either an alphabetic or numeric character

in position 7 would eliminate a VIN user’s ability to make this determination and would create

considerable confusion for VIN system users. (Daimler’s suggestion that the manufacturer have

the option of choosing which character in the second section of the VIN to change from

alphabetic to numeric or vice versa, would be even more confusing to VIN users). Under the

approach suggested by Daimler and BMW, VIN users would be unable to use the seventh VIN

character to determine the model year of makes and models of vehicles manufactured in both the

30 year span of the current VIN system and in the 30 year span contemplated for the VIN system

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