Interpretation ID: aiam3103
PACCAR
Inc.
Business Center Building
P.O. Box 1518
Bellevue
Washington 98009;
Dear Mr. McDonald: This is in response to your letter of May 22, 1979, concerning Federa Motor Vehicle Safety Standard No. 115, and in confirmation of your telephone conversation with Mr. Schwartz of my office.; You have asked whether a manufacturer must designate a vehicle a 'incomplete vehicle' if, although it is shipped in an incomplete form, its completed type is known. The 'incomplete vehicle' type was established to deal with situations where the manufacturer did not know what the vehicle's final type would be when it assigned the VIN. If the final form the vehicle will take is known to the manufacturer, it may identify that type in the VIN, or it may designate it as an incomplete vehicle. The agency would prefer, however, that the final type be indicated.; There is no requirement that use of a particular vehicle typ designation for VIN purposes be consistent with any other documentation regarding shipment or sale of vehicles manufactured in more than one stage, except that the actual VIN must be used where it appears on the documentation. For example, a vehicle may be designated an incomplete vehicle for the purposes of the NHTSA certification requirements and a truck for the purposes of the VIN requirements.; You have also asked the agency to confirm that engine horsepower nee not be directly or indirectly decipherable from the VIN. This is essentially correct. 'Engine type' is defined in S3 of the standard to mean a power source with defined characteristics such as fuel utilized, number of cylinders, displacement and net brake horsepower. Thus, encoding an engine manufacturer's basic model number would be sufficient. There remains, however, a question as to the point at which two engines with the same characteristics except for horsepower become two different engines. The agency intends to resolve this question in a notice in the Federal Register.; Sincerely, Frank Berndt, Chief Counsel