Interpretation ID: nht90-3.33

TYPE: Interpretation-NHTSA

DATE: July 27, 1990

FROM: Thomas R. Mounteer -- Esquire, Stovall & Spradlin

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re Heritage Motor Cars, Inc./VIN for Legacy Passenger Vehicles (NEF-31KNU IR 831-836)

ATTACHMT: Attached to letter dated 2-1-91 from Paul Jackson Rice to Thomas R. Mounteer (A37; Std. 115)

TEXT:

This firm has been retained to assist Heritage Motor Cars, Inc. ("Heritage") in complying with the Office of Vehicle Safety Compliance's certification review program. We are coordinating those efforts through Karen Nuschler in that office.

As part of its compliance efforts, Heritage will ensure that it has fully satisfied Part 567's certification requirements. Our purpose in writing this letter is to ensure that VINs are properly assigned to Legacy vehicles under Part 565. I discussed th is matter with Ms. Dot Nacoma of your office, and she requested that I write to request an interpretation from the agency.

Ms. Nacoma explained that Heritage's method of manufacturing the Legacy complicates the assignment of VINs. As I explained to Ms. Nacoma, Heritage builds its Legacy on the frame of used Chevrolet Camaros. I have enclosed photocopies of Heritage's broch ure for its Legacy assembly kits by way of illustration. You should be aware, however, that in its finished Legacies, Heritage uses new engines and transmissions purchased from GM's Parts Division. With that caveat, the diagrams on page two of the encl osure illustrate what portion of the donor car remains.

My preliminary thought was that the Heritage Legacy would need an entirely unique VIN for purposes of Part 567 certification. However, I recognize that the donor car's VIN is retained for so-called "altered vehicles," although Heritage manufacturing pro cess does not constitute vehicle alteration. Nevertheless, Ms. Nacoma pointed out that a discrepancy between the confidential VIN which GM stamps on the Camaro frame (a number not regulated by NHTSA) and the VIN used for purposes of Part 567 certificati on might thwart theft prevention efforts.

Your interpretation of the proper approach for assigning VINs for Heritage's Legacy vehicles would be very much appreciated. I would be pleased to provide any additional information which might be required in this regard.

Attachment

Heritage Motor Cars brochure for Legacy assembly kits (Text and graphics omitted)