Thread: NHSTA
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#2 Re: NHSTA
12-02-2012, 08:23 PM
The checklist for any State in the USA before a Title and registration can be issued would be.
Does the vehicle have EPA certification?
Is the manufacturer meeting federal procedural regulations 49 CRF parts 565 and 566?
I can assure you the list NJ created is not valid.
Such a list would have to have vehicles that have current EPA certificates, but only if the manufacturer of those meets the requirements of 49 CRF parts 565 and 566.
I believe that the EPA should not offer any certificates, to any manufacturer that is not compliant to federal transportation laws.
I also believe it is the states responsibility to verify any claim of formal operations in their state made to the NHSTA. That being before the EPA offers a certificate on a vehicle they should validate with the NHSTA and further the NHSTA should not propagate part 566 with information about the state agent of process until they verify with that state such a business entity in fact exists.
The multiple uses of the term “manufacturer” is causing confusion.
The EPA needs to add a field, that needs to be the “agent of certification” that being who stands behind the application and testing data. Then the terms “manufacturer” can only represent what must match part 566 of 49 CRF and only when the state of operation validates the existence of that agent of process. The term OEM has to match the WMI listed with the SAE.
I was told that this is not possible because the federal government cannot dictate to the federal government what to do. They cannot enforce federal regulations on themselves? I am being sarcastic, the issue is that the EPA, NHSTA, SAE are not functionally aligned, they confuse the states and the results are pretty obvious in NJ.
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