Interpretation ID: nht79-4.50

DATE: 03/28/79

FROM: D. J. ARNOLD -- VESELY COMPANY DIRECTOR OF PRODUCT DEVELOPMENT

TO: FREDERIC SCHWARTZ -- OFFICE OF THE CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

TEXT: Dear Mr. Schwartz:

With issuance of Docket No. 1-22; Notice 8, relating to Vehicle Identification Numbers I must assume the NHTSA is getting closer to "finalizing" FMVSS No. 115 notwithstanding the VIN litigation upcoming in the U.S. Court of Appeals for the Fourth Circuit. As such, and in follow-up to my several letters and telephone conversation with you on January 9, 1979 I am again requesting official NHTSA written replies to these as soon as possible to enable our small company to try and comply with the Federal requirements.

To date, I have not received approval of our requested first three digit assignments (letter of October 30, 1978) as required by the standard and I have not received written permission to utilize digits 12 and 13 for our own in-house use (letter of December 11, 1978). Further, I have never received an official answer to my letter to President Carter other than a post card from Secretary Adams saying he will be replying.

All in all, not much action to help our company comply with these Federal mandates. If our company is going to be able to meet the effective date of September 1, 1980 we must have some answers now! Docket No. 1-22; Notice 8 has done nothing to alleviate or reduce this company's burden as I interpret the impact of it. Since we not only manufacture motor homes (MPV's) but recreational trailers as well, we must institute this 17 digit system even though the chassis manufacturer would assign his VIN. We cannot stay with our current VIN system for one product and change to a completely different VIN system for our other products.

Your replies will be anxiously awaited to enable us to continue the necessary work to comply with FMVSS 115 as it now stands by the effective date of September 1, 1980.

Very truly yours,