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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

Comment:

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

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