the first position of the second section, for example, could stand for the make, type of trailer,
body type, length and axle configuration of one variation of trailer made by a given manufacturer
while a “C” could stand for that same information relating to a different trailer.
The NATM comments made the agency aware of the fact that there is no current need to
include low speed vehicles (LSVs) in the vehicles that must use an alphabetic character in
position number 7 of the VIN as required by today’s final rule. These vehicles will now be
treated the same as larger trucks, buses, trailers, and motorcycles.
7. Modification in Gross Vehicle Weight Rating Classes
NESCAUM asked for a change in “Table II – Gross Vehicle Weight Rating Classes” of
49 CFR Part 565.6(b) by adding a break point at 8,500 pounds in one of the classes listed to
distinguish whether or not a truck is light or heavy duty.
Agency Analysis and Response:
The classification system in Table II of Part 565 has been in existence for nearly 30 years
and a great deal of data has accumulated in various places based on this system. The agency’s
experience with this classification system suggests that the change advocated by NESCAUM
could have a significant effect on the various data systems that are built on this system. Any
change to this system would require a complete and thorough analysis of the possible impact of
that change on these data systems. This was not an issue addressed in the petition that initiated
this rulemaking or in the NPRM. The agency is not acting on this recommendation at this time,
not because the recommendation is deemed to lack merit, but instead because of the need to
publish this final rule promptly. This issue will be part of the comprehensive review of the VIN