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Interpretation ID: aiam3260

Mr. James W. Lawrence, White Motor Corporation, 35129 Curtis Boulevard, Eastlake, Ohio 44094; Mr. James W. Lawrence
White Motor Corporation
35129 Curtis Boulevard
Eastlake
Ohio 44094;

Dear Mr. Lawrence: This responds to your letters dated March 11, 1980, and March 21 1980,asking several questions about Federal Motor Vehicle Safety Standard No. 115, *Vehicle identification number*.; Your first question relates to the number sequentially assigned to th vehicle by the manufacturer as required by S4.5.3.3 of the standard. You wish to know whether after assigning a number to a vehicle prior to its manufacture, the number may be cancelled if the vehicle is not actually manufactured. The answer is yes. This is permissible under the standard so long as the number is not reassigned to another vehicle, thereby destroying the sequence.; You also wish to know if White may assign a vehicle identificatio number to glider kits which it manufactures. Section 571.7(e) and (f) of Title 49, Code of Federal Regulations set forth the criteria for determining whether the vehicle created from a glider kit is to be considered a new vehicle or the original vehicle. If the vehicle is considered new, it must comply with all applicable Federal motor vehicle safety standard, including the requirement the a new vehicle identification number be assigned (Standard No. 115). If, however, the vehicle is not considered new, the vehicle identification number originally issued for the vehicle must be the one that is assigned. (See section 109(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, as amended.); Sincerely, Frank Berndt, Chief Counsel