creating unworkable difficulties in any broad category of other situations. NYDMV
acknowledged in its comments that even in cases of grey market vehicles with driver facing VIN
plates it has encountered, the VIN remains readable, although with some difficulty. As such, the
agency is not specifying the direction in which the VIN plate must face in this rule.
13. Companies That Vacillate Between High-Volume and Low-Volume Production
Prevost described a situation that it indicated may be unique to bus/motor coach
manufacturers. Because there are so few manufacturers in this category and the market is
relatively small, a manufacturer, at least under the current Part 565 with its 500 vehicle dividing
line between small and large manufacturers, may one year be a small manufacturer and the next
a large manufacturer. As a small manufacturer under current Part 565, it is required to use a six
character manufacturer identifier. As a large manufacturer, it is required to use a three character
manufacturer identifier. Prevost recently became a large manufacturer under the current Part 565
and is concerned that it might have to return to using a small manufacturer identifier and change
its whole VIN structure. It urged that the dividing line between low-volume manufacturers and
high-volume manufacturers be set at a threshold lower than the current 500 vehicles for
manufacturers of vehicles greater than 4536kg GVWR.
Agency Analysis and Response:
Prevost is principally concerned that it have one consistent approach to VINs and not
have to switch between low-volume manufacturer VINs and high-volume manufacturer VINs.
The agency believes that raising the threshold between low-volume manufacturer and high-
volume manufacturer to 1,000 vehicles will address the situation described by Prevost, at least
for some bus/motor coach manufacturers. However, the agency believes that if we lower the