Interpretation ID: aiam3086
Vesely Company
2101 N. Lapeer Road
Lapeer
Michigan 48446;
Dear Mr. Gibbard: This is in confirmation of your telephone conversation with Mr Schwartz of my office on August 6, 1979, and the previous telephone conversations between Mr. Schwartz and Mr. Arnold, formerly of your company, and Mr. Erickson of our Office of Rulemaking and Mr. Arnold. It also serves to supplement the letter from Michael Finkelstein, Associate Administrator for Rulemaking, to the president of your company, Mr. McCollough.; Barring an order of the Court of Appeals for the Fourth Circuit, w anticipate no changes in the rule beyond those made in Notice 8. Further, the contract with the Society of Automotive Engineers to act as the NHTSA's agent in distributing manufacturer identifiers, which Mr. Arnold was advised the agency was negotiating, has been entered into. We are therefore able to confirm the answer to your company's remaining questions with certainty. The technical questions you raised will be answered first, as we understand you would prefer to have these answers in writing also.; 1. You have asked whether Vesely can use the first two characters o the sequential number (the 12th and 13th characters of the VIN if one includes the check digit) for internal company purposes as the number of vehicles produced is more than 500, but never exceeds 9,999 of a particular model annually. There is nothing in the standard which precludes utilizing the 12th and 13th characters for internal purposes so long as the agency is advised which characters are to be used and that they are to be disregarded.; 2. You have also advised us that Vesely desires to use severa manufacturer identifier the codes beginning with the letter V. When the NHTSA published its rule establishing the manufacturer identifier system on August, 17, 1978, the Society of Automotive Engineers (SAE) immediately submitted a list of approximately 500 identifiers on behalf of vehicle manufacturers. These identifiers had been previously assigned to manufacturers by the SAE in their role as assigner of world manufacturer identifiers on behalf of the International Standard Organization. Unfortunately, the configuration Vesely proposed was reserved by the SAE at that time.; Because of the substantial experience the SAE has had in this area, th NHTSA has contracted with them to assign the remaining manufacturer identifiers. If you would write to the SAE at the address given below, advising them of the types of vehicles you are now producing or intend to produce, they will assign your manufacturer identifiers at no charge. Please write to:; >>>Society of Automotive Engineers 400 Commonwealth Avenue Warrendale, Pennsylvania 15096 Attention: Leo Ziegler<<< I trust this information answers the questions you have concerning th VIN. Please contact us if you have any further questions.; Sincerely, Frank Berndt, Chief Counsel