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Study finds VIN/ emissions rules constrain low‑volume kit car registration; California precedent flagged
Summary
A consultant study and DMV panel told the Senate Transportation Committee that federal and California emissions certification requirements, not NHTSA safety waivers, are the principal constraint on low‑volume manufacturers and kit cars seeking Vermont VINs and registration.
A state‑commissioned study of low‑volume and kit vehicles presented to the Senate Transportation Committee on Feb. 4 said Vermont already has VIN assignment processes for exceptional cases but that emissions certification — governed by the Clean Air Act and controlled by the EPA and California Air Resources Board (CARB) — creates a barrier for low‑volume manufacturers who would otherwise benefit from NHTSA safety exemptions.
"The safety side was really given some ability to pass and be exempt from crash tests and some very other expensive, efforts for low volume manufacturers," Jonathan Slayson of RSG told the committee, referencing federal FAST Act and related guidance. But Slayson and DOT panelists explained that emissions compliance is a separate issue: "The Clean Air Act prohibits the use of engines that are not certified," he said, and only EPA or CARB can certify engine configurations.
Slayson said Vermont already assigns limited in‑state VINs in problem cases (for example, illegible or missing VINs) and that such VINs are typically not recognized outside the issuing state. He described inspection pathways — such as using approved inspection stations to verify roadworthiness — but emphasized that emissions verification for vehicles newer than about 16 years often relies on an OBD (on‑board diagnostics) test tied to a known certified engine configuration.
The study noted California’s approach (SB 100 and related practices) as a possible model: California allows well‑defined limited waivers for individuals to self‑certify a vehicle’s emissions 'model year' design so that certain historic or individually built vehicles can be registered, a process the consultant said has not been widely challenged by federal authorities to date.
Lieutenant Jeremy Scharnick of Vermont State Police — who participated in the study on the DMV/enforcement side — told the committee that DMV issues VINs in a limited number of cases annually (he estimated fewer than 20–30 per year) and that DMV does not issue EPA or CARB engine compliance labels; instead, DMV relies on documentation, invoice trails and inspection results to assign state VINs in problem or home‑built cases.
Ending: The committee asked for follow‑up on definitions, the likely volume of affected vehicles, and whether Vermont could adopt California‑style approaches without creating federal compliance risk; panelists said more coordination and careful legal framing would be needed before any statutory change.
