ID: nht90-3.25

TYPE: Interpretation-NHTSA

DATE: July 19, 1990

FROM: Robert B. Roden -- Roden & Hayes

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re 15 USCS Section 1403

ATTACHMT: Attached to letter dated 6-3-77 from J.J. Levin, Jr. to L.J. Strobel (VSA 114); Also attached to letter dated 12-3-90 from P.J. Rice to R.B. Roden (A36; Std. 205)

TEXT:

I am writing to request your opinion regarding 15 USCS Section 1403. I am specifically interested in your opinion regarding whether the federal law requires some form of certification on every replacement item of motor vehicle equipment. It appears fro m the statutory language that such is the case.

We appreciate your opinions with respect to this matter.

ID: nht90-3.26

TYPE: Interpretation-NHTSA

DATE: July 23, 1990

FROM: Timothy Murphy -- Chairman Engineering Committee - Lights, Transportation Safety Equipment Institute, Peterson Manufacturing Company

TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated August 31, 1990 from P.J. Rice to T. Murphy (A36; Std. 108)

TEXT:

The Engineering Committee of the Transportation Safety Equipment Institute (TSEI) has reviewed your letter of February 26, 1990 to the Bargman Company. This specific letter was in response to a question from Bargman dated December 13, 1989 in which they specifically asked if an amber reflex reflector was permitted as an additional reflector on the rear of vehicles covered by FMVSS108.

Your conclusion was that the installation of an amber tail lamp lens with an amber reflector would not constitute a noncompliance with Standard No. 108. We respectfully disagree for the reasons stated below.

You are correct in your statement that no additional reflective device may be installed that impairs the effectiveness of reflective equipment required by Standard No. 108. You then state, "It does not appear to us that an amber tail lamp lens with an a mber reflector would create an impairment."

While amber is a permissible color for rear turn signal lamps, the referenced rear turn signal lamp is a flashing device. We are unaware of any state law or federal law which permits a steady burning amber signal to the rear and, therefore, your interpr etation is a distinct departure from past practice.

We respectfully suggest that a steady burning lamp or reflector to the rear clearly would create confusion for following drivers. For example, on vehicles under 80 inches wide, the only devices required on the rear are two tail lamps and two rear red re flectors which are, in effect, operable at all times. That is, they are steady burning and represent a continuous signal.

If one now introduces two additional amber reflectors, following motorists would then see the two required red tail lamps and two amber reflectors which would be about 2 1/2 times brighter than the required red reflectors if we consider the luminous tran smission difference between the red and amber colors. In short, the amber auxiliary add-on reflectors would normally be much brighter (by a factor of 2 1/2 times) than the required red reflector. It is our strong and unanimous conclusion that this woul d certainly represent an impairment of a required device.

The states of California, Michigan, Minnesota, Pennsylvania, and many other

states, clearly specify that reflectors, visible from the rear of a vehicle, shall be red. We know of no instance where amber rear reflex is specifically permitted by any state.

The last sentence in your February 26th letter to the Bargman Company states, "This agency presently has no plans to specify yellow as an alternate color for rear reflex reflectors." We suggest that an agency interpretation letter which permits yellow o r amber reflex reflectors on the rear of a vehicle could be the source of considerable confusion. For example, a manufacturer might elect to install an auxiliary amber reflex on the rear of a vehicle manufactured in a state where the law is silent on th e subject of rear reflex color. However, when the user then travels to one of the many states which clearly prohibit steady burning amber lamps or reflex to the rear, they may find themselves subject to violations of specific state laws. You should als o consider that if amber rear reflex is permitted as an auxiliary add-on device, the next logical step might well be a steady burning amber auxiliary lamp on the rear of vehicles. We submit that such color to the rear would create an obvious impairment of the required devices. For the reasons outlined above, we would ask that you review the February 6, 1990 interpretation.

ID: nht90-3.27

TYPE: Interpretation-NHTSA

DATE: July 23, 1990

FROM: C.D. Black -- Manager, Product Legislation and Compliance, Jaguar Cars Inc.

TO: Administrator -- NHTSA

TITLE: Re Request for Reconsideration of an Interpretation FMVSS 114 Docket 1-21 Notice 9

ATTACHMT: Attached to letter dated 10-12-90 from P.J. Rice (Signature by K.M. Weinstein) to C.D. Black (A36; Std. 114); Also attached to a copy of 49 CFR Part 571.114 and 55 FR 21868 (May 30, 1990) (text omitted)

TEXT:

Jaguar Cars Ltd of Coventry, England (herein after referred to as Jaguar) request that NHTSA review their interpretation on pages 21872/73 of the Federal Register of the conditions under which a mechanical emergency release may be installed on a transmis sion shift lever interlock.

Jaguar regards the objective of the amendment as fair and reasonable, however, because Jaguar manufacture vehicles for sale worldwide with either manual or automatic transmission, we will continue to install an anti-theft lock operating on the steering c olumn. Jaguar therefore plan to comply with the amended standard by means of a spring-loaded electrical interlock operating on the console-mounted automatic transmission shift lever together with a revision to the steering column lock to prevent removal of the key unless the shift lever is in 'park'. When the ignition is next switched 'on', operation of the brake pedal produces an electrical signal to disengage the interlock and hence allow the shift lever to be moved.

However, as Honda, Mazda, Nissan, Subaru and Toyota have previously stated in the docket, the use of an electrically operated interlock acting on the shift lever could, in the event of a battery or electrical failure, cause problems unless a mechanical e mergency release is provided. If the vehicle is tightly parked, the shift lever placed in 'park' to remove the key, and the battery subsequently discharged, it might then be necessary to "drag" the vehicle on locked wheels to gain access before a charge d battery or jumper leads could be connected to remove it from its disabled position.

Jaguar had anticipated that a manual emergency release which, when required, must be activated against spring pressure with one hand using a tool, while allowing the shift lever to be moved out of 'park' only by a simultaneous movement of the other hand, would maintain the declared intent of the amendment to prevent "rollaway" accidents. The theft protection of any (Jaguar) vehicle so equipped would not be degraded because the steering column lock and ignition/starter system remain immobilized. With t his or a similar combination of equipment there is no merit in requiring the shift lever interlock emergency release to be operable only by the key used to control the vehicle (emphasis added).

Jaguar request your consideration that the total objectives could be met by an interpretation along the following guidelines:

"In the case of an electrically operated interlock on the transmission shift lever, where the primary theft protection is provided by a steering column lock, the emergency release may be operated by a single action requiring the use of the key used to co ntrol the vehicle. Alternatively, a mechanical emergency release is allowable provided that it requires the use of a separate implement or tool and the simultaneous use of two hands to release the shift lever."

In view of the demanding timescale given by the Agency's interpretation on "mechanical override system's" in the final rule, Jaguar respectfully request the earliest consideration of our petition.

ID: nht90-3.28

TYPE: Interpretation-NHTSA

DATE: July 24, 1990

FROM: Roman L. Cepeda

TO: Frank Berndt -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-30-90 from P.J. Rice to Roman L. Cepeda (A36; Part 591)

TEXT:

I was advised by Guam Customs to write and inquire from your office the requirements to import stainless steel jeep body from the Philippine.

The stainless steel jeep body are molded in the Phillipine in 8 to 12 parts. The molded jeep body would then be put together on Guam. The engine, chassis, all other parts other than the stainless steel body are from Guam.

The stainless steel jeep body is not a motor vehicle and is not required to meet any provision of the U.S. 49 CFR Part 400 to 999.

Perhaps, you could clear this misunderstanding with Guam Customs with a simple letter advising them that I can import stainless steel jeep body from the Philippine with out violating the Federal Motor Vehicle Safety Act of 1966 and U.S. 49 CFR Part 400 t o 999.

Thank you for your assistance and cooperation.

ID: nht90-3.29

TYPE: Interpretation-NHTSA

DATE: July 25, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; signature by Stephen P. Wood TO: William Waltz -- Wagner Division, Cooper Industries, Inc.

TITLE: None

ATTACHMT: Letter dated 4-12-90 to Stephen P. Wood from William Waltz

TEXT:

This is in reply to your letter of April 12, 1990, stating that Wagner Division "would like to petition N.H.T.S.A. for a 'Determination of Inconsequentiality' for non-compliance."

Specifically, Wagner wishes to manufacture round sealed beam headlamps (not "bulbs" as you call it) for Lectric Limited, a small parts business geared towards the antique automobile hobby. The headlamps are intended for use on "antique automobiles". We understand that term to mean any automobile manufactured in 1940 and subsequent model years that was originally equipped with round sealed beam headlamps. Although the headlamps would be designed to conform to current specifications, those of SAE Stand ard J579c, the word "top" would be used on the 7-inch diameter headlamp instead of the designation "2CI" (you mean "2Dl"), the numeral "1" for "1C1" on the single beam 5 3/4-inch diameter headlamp, and the numeral "2" for "2C1" on the dual beam 5 3/4-inc h diameter headlamp. The lamps would not bear "DOT" identification. Lectric Limited is willing to "ink stamp" DOT, 2D1, 1C1, and 2C1 "on either the face and or the rear" of each headlamp so that they would not be mistaken for, those conforming to SAE J 579a, and to print instructions for purchasers explaining the difference. Lectric Limited is also willing to insure that the headlamps are marketed only through antique auto specialty retailers.

First, let me explain that your request cannot be considered as one for a determination of inconsequentiality. These determinations are made after-the-fact in order to determine whether a manufacturer must fulfill statutory obligations which include rep lacement, repurchase, or repair of the already-manufactured noncompliant product. What you seek is permission to produce motor vehicle equipment that fails to comply with labeling requirements. Unfortunately, the agency has no exemption provisions whic h can address this issue. We have authority to exempt manufacturers of motor vehicles from compliance for a temporary period, but we have no authority to exempt manufacturers of motor vehicle equipment, on either a temporary or permanent basis. Further , we cannot waive the marking requirements of sections S7.2 and S7.3 of standard No. 108, even for the limited purpose and subject to the restrictions you discuss.

After due consideration of the matter, we believe that you have no choice other than to conform to the marking requirements of Standard No. 108. Although neither the marking nor the performance of J579c headlamps replicates that of J579a headlamps, I hop e that auto enthusiasts will be willing to accept the marking that goes with the improved performance.

ID: nht90-3.3

TYPE: Interpretation-NHTSA

DATE: June 29, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Ed McCarron -- Western Star Trucks Inc.

TITLE: None

ATTACHMT: Telefax dated 6-22-90 to Dee Fujita from Ed McCarron attached.

TEXT:

This responds to your letter asking about the application of Safety Standard No. 302, Flammability of Interior Materials, to a particular mattress design, and how the mattress would be tested under the standard. I regret the delay in responding.

Paragraph S4.1 of Standard 302 sets forth a listing of the vehicle occupant compartment components that must be certified as complying with the flammability resistance requirements of paragraph S4.3. Paragraph S4.1 includes a reference to "mattress cove rs." You ask whether NHTSA would consider six components of your mattress design to be included in the term "mattress cover" and thus subject to Standard 302. (The first five components you ask about, and a portion of the sixth, satisfy the criterion i n S4.2 of being within 1/2 inch of the occupant compartment air space.)

As we understand your sketch, the first three components (which you called the "cover," "foam" and "foam backing") encase the mattress core, or filling. As such, if our understanding is correct, these three constitute the mattress ticking, which we cons ider as the fabric case permanently enclosing the filling of a mattress. NHTSA has said in past interpretations of Standard 302 that the term "mattress cover" includes both a removable covering put over a finished mattress and the mattress ticking. Thu s, the first three components would be subject to the standard.

These three components, which you said in a telephone conversation are quilted together, would be tested separately under S4.2.1 of the standard if they do not adhere to other materials at every point of contact. (The fact that these three are quilted, or stitched, indicates to us that they do not so adhere.) If any of these components adhere to other material at every point of contact, then it would be tested as a composite with the other material.

The fourth component in your sketch is the mattress "fill." Paragraph S4.1 of the standard lists mattress covers only. NHTSA has consistently interpreted S4.1 as not including the mattress filling.

The fifth component is a fabric "corner reinforcement" that appears to be approximately two inches in length and stitched on the outside of the mattress cover. NHTSA indicated in interpretative letters of Standard 302 dated December 15, 1972 and May 1, 1972 that a component that is "incorporated into" a component that is listed in S4.1 is subject to the standard. (The agency said in the December 1972 letter that "mattress cover" includes tufting, since tufting is incorporated into mattress covers.) S ince the fifth component is sewn to the corner of the mattress

and appears to be made part of the mattress cover, we believe that the corner reinforcement is incorporated into the mattress cover. Thus, the fifth component would be subject to the standard. If it does not adhere to another material at every point of contact, it is tested separately under S4.2.1.

The sixth component is the "fill backing" which appears to be an internal divider between the mattress fill and the springs. It appears from your sketch that the fill backing is not part of the mattress ticking, because the backing is inside the mattres s and is separate from the mattress ticking. Thus, we conclude the sixth component is excluded from the standard.

I hope this information is helpful.

ID: nht90-3.30

TYPE: Interpretation-NHTSA

DATE: July 25, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; signature by Stephen P. Wood

TO: Wayne Brush -- Director, Material Management, Conceptor Industries, Inc.

TITLE: None

ATTACHMT: Letter dated 4-20-90 to Clive Van Orden from Wayne Brush

TEXT:

Thank you for your letter to Mr. Clive Van Orden of our Office of Vehicle Safety Compliance seeking an interpretation of this agency's requirements for a vehicle identification number (VIN), as set forth in 49 CFR Part 565, Vehicle Identification Number - Content Requirements, and Standard No. 115, Vehicle Identification Number - Basic Requirements (49 CFR S571.115). You stated that your company plans to modify vans manufactured by General Motors (GM) to produce electric powered vehicles for sale in th e United States. You asked whether these vehicles may use the GM world manufacturer identifier (WMI), as well as a check digit, model year identification, and production sequence codes assigned by GM, and use an X as the engine type code to show that th e vehicles were actually manufactured by your company. As explained below, the answer to your question is no.

S4.1 of Standard No. 115 reads as follows:

Each vehicle manufactured in one stage shall have a VIN that is assigned by the manufacturer. Each vehicle manufactured in more than one stage shall have a VIN assigned by the incomplete vehicle manufacturer. Vehicle alterers, as sp ecified in 49 CFR S567.7, shall utilize the VIN assigned by the original manufacturer of the vehicle.

As described in your letter, Conceptor Industries plans to produce completed electric powered vehicles by using an assemblage of motor vehicle equipment produced by GM, including frame and chassis structure, steering, suspension, and braking systems. Ho wever, the assemblage provided to your company by GM would not include a power train. The absence of a power train means that this assemblage would not be an "incomplete vehicle," as that term is defined in S3 of Standard No. 115, so the Conceptor elect ric vehicles would not be considered to be manufactured in more than one stage. Your company would not qualify as a vehicle alterer, based on the information provided in your letter, because GM would not have already certified the vehicles modified by yo ur company. Thus, the electric powered vehicles produced by Conceptor would be considered to be vehicles manufactured in one stage, and the VIN for these vehicles would have to be assigned by Conceptor, the manufacturer of these vehicles.

Part 565 specifies the format and content of the VIN that Standard No. 115 requires your company to assign to its electric powered vehicles. In relevant part, 49 CFR S565.4 provides that:

The VIN shall consist of four sections of characters which shall be

grouped accordingly: (a) The first section shall consist of three characters which occupy positions one through three (1-3) in the VIN. This section shall uniquely identify the manufacturer, make and type of the motor vehicle if its manufacturer produces 500 or more motor vehicles of its type annually. If the manufacturer produces less than 500 motor vehicles of its type annually, those three characters, along with the third, fourth, and fifth characters of the fourth section shall uniquely identify the manufacturer, make and type of the motor vehicle. Under the approach suggested in your letter, GM would be identified as the manufacturer of the vehicle by the first three characters of the VIN, and the eighth character would indicate that Conceptor was the actual manufaCcturer. This approach would be plainly inconsistent with the requirements of S565.4 quoted above, because the regulation requires the first three characters in the VIN to identify the vehicle manufacturer. Your company is the manufacturer of these vehicles, not GM, so your company mus t be identified by the first three characters of the VIN. Furthermore, S565.4(b) provides that the eighth character in the VIN shall uniquely identify specified attributes of the vehicle, not identify the manufacturer. Hence, the approach suggested in y our letter would not comply with this agency's VIN requirements.

Additionally, you informed Dorothy Nakama of my staff in a July 3, 1990 telephone conversation that, at least in the initial years of your company's production of these vehicles, the annual production will be less than 500. If this is the case, you shou ld note that S565.4(a) requires your company to use not only the first three characters of the VIN to uniquely identify the manufacturer, make and type of the motor vehicle, but also the 12th, 13th, and 14th characters of the VIN as well to make this uni que identification.

I hope this information is helpful. If you have any further questions or need any additional information, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

ID: nht90-3.31

TYPE: INTERPRETATION-NHTSA

DATE: 07/25/90

FROM: JEFF CORNELL -- ENGINEERING, THE BARGMAN COMPANY

TO: TAYLOR VINSON -- LEGAL COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 8-23-90 TO J. CORNELL FROM P. J. RICE; (A36; STD. 108); ALSO ATTACHED TO DOCUMENT SEARCH REPORT (INFORMATION OMITTED)

TEXT:

My company manufactures lighting products for recreational vehicle manufacturers, OEM's. Due to recent customer requests, we are asking for a clarification on the following FMVSS 108 changes published May 15, 1990.

S5.1.1.31 (amended) states: On a motor vehicle, except a passenger car, whose overall width is 80 inches or more, measurements of the functional lighted lens area, and of the photometrics, of a multiple compartment stop lamp, and a multiple compartment turn signal lamp, shall be made for the entire lamp and not for the individual compartments.

Prior to this change, the maximum values increased as the number of lighted compartments Increased. As the new change states above, the photometric requirements are to be on the entire light, does this include the maximums also? If this is the case, a single compartment light must be less than the 300 maximum candlepower, and a 5 compartment light would also need to be less than the 300 value. This was addressed in the second full paragraph on page 20159 of the Federal Register for the minimum requirements, but there is no reference to the maximums. Please clarify.

Here is an example of another question we have:

Let's say a manufacturer is purchasing a single compartment light, that does not meet the new lens area requirement, for use in a molded bumper or fiberglass cap. If he is using 3 of these lights per side as stop lamps, and the combined area of the 3 is greater than the 75 square centimeters (from SAE J1398 MAY85), is this legal per the new requirements? Along the same line, If the vendor making these lights mounts the individual lights in a molded housing, are we correct in assuming that this would now classify as a multiple compartment lamp? If adding a housing to these lights will make it a multiple compartment lamp, then how is it different if it is installed into a molded bumper or fiberglass cap?

At the beginning of the amendment in the summary, it states that the lens area is 12 square inches, however, in the SAE standard J1398 MAY85 it states 75 square centimeters. When the two areas are converted into like units they do not match up. Which area is correct? (75 square centimeters = 11.625 square inches, 12 square inches = 77.42 square centimeters).

We would appreciate your earliest response, as we have customers waiting for answers concerning the above items.

ID: nht90-3.32

TYPE: Interpretation-NHTSA

DATE: July 27, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Ron Boucher -- Energy Savings Systems

TITLE: None

ATTACHMT: Letter dated 5-29-90 to NHTSA Office of Chief Counsel from R. Boucher; (OCC 4837); also attached to letter dated 5-17-90 to Miss Carnes from R. Boucher; (OCC 4824) TEXT:

Thank you for your letter asking whether the products you plan to market would comply with the laws and regulations administered by this agency. As explained below, the laws and regulations administered by this agency would not be applicable to these pro ducts.

Enclosed with your letter were two brochures describing the "Signal Flash" personal identification lights. The brochure included pictures and descriptions of several different types of battery-powered lights that are small enough to be carried on one's person, and include straps that make them suitable to be carried on one's arm, around one's wrist, or inserted into a life preserver. The brochures describe these "Signal Flash" lights as suitable for use in "diving, mountaineering, jogging, sailing, wi ndsurfing, cycling, fishing, car breakdown, life jacket, etc."

The National Traffic and Motor Vehicle Safety Act (the Safety Act) authorizes this agency to regulate "motor vehicles" and items of "motor vehicle equipment." Section 102(4) of the Safety Act (15 U.S.C. 1391(4)) defines "motor vehicle equipment", in par t, as:

any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to t he motor vehicle...

Your "Signal Flash" lights are plainly not a "system, part, or component of a motor vehicle as originally manufactured," nor are they a "similar part or component manufactured or sold for replacement or improvement" of an original equipment part of a mot or vehicle. The issue is whether these lights would be considered an "accessory" within the meaning of the Safety Act. In determining whether an item of equipment is considered an "accessory," the agency applies the relevant statutory language and the two following criteria: first, whether a substantial portion of the expected uses of the item are related to the operation or maintenance of motor vehicles, and second, whether the item is intended to be used principally by ordinary users of motor vehic les.

In evaluating the first criterion, the product literature enclosed with your letter emphasizes the versatility of these personal identification lights. While these lights occasionally may be used in connection with a motor vehicle breakdown or repair, m ost of the suggested uses involve sports activities that have nothing to do with a motor vehicle. Thus, a substantial portion of the expected uses of the light would not appear

related to the operation or maintenance of a vehicle, so these "Signal Flash" lights would not be considered items of "motor vehicle equipment." This conclusion means that the "Signal Flash" lights are not subject to any of the laws and regulations admin istered by this agency.

You may wish to consult the U.S. Consumer Product Safety Commission to learn if they have any requirements applicable to these lights. That agency protects the public against unreasonable risks of injury from consumer products. You may write to the Con sumer Product Safety Commission at 5401 Westbard Avenue, Bethesda, MD 20207, or contact them by telephone at (301) 492-6580.

I hope this information is helpful. If you have any further questions or need any additional information, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

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)