OFF THE WIRE
AAMVA response- reclassification of motorcycles:
http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ad1065
American Association of Motor Vehicle Administrators Neil D. Schuster Charles O’Donnell, Chair of the Board President and CEO Registrar of Motor Vehicles New Brunswick Department of Public Safety April 1, 2010 The Honorable Victor Mendez Administrator, Federal Highway Administration U.S Department of Transportation Dockets Management Facility Room W12-140 1200 New Jersey Avenue, SE Washington, DC 20590
Re: Docket # FHWA-2010-0010 Reclassification of Motorcycles (Two and Three Wheeled Vehicles) in the Guide to Reporting Highway Statistics
Dear Administrator Mendez:
The American Association of Motor Vehicle Administrators (AAMVA) believes there are some serious obstacles to facilitated reclassification of motorcycles in the Guide to Reporting Highway Statistics. The initial difficulty lies in the fact that definitions and procedures for motorcycles vary widely from state to state and most states do not break down motorcycle classifications the way they are described in this request for comments. AAMVA appreciates the Federal Highway Administration’s desire to reclassify motorcycles. However, because all states are required to report statistics to FHWA, the discrepancy in classification and reporting requirements between states could skew statistics and create administrative difficulties for registering and reporting vehicles. We are available to work with FHWA staff to address these issues and help your agency develop a system that will allow FHWA to obtain accurate and meaningful information from the states.
Specifically, AAMVA has concerns with the following definitions:
Motorcycles – The definition of motorcycles for registration purposes varies widely from state to state. At least some states require a motorcycle to have a seat that the rider straddles. Some state laws also allow a steering wheel; however, some may not specify, meaning those states would not restrict registration to only those vehicles with handle bars. Many states do not include the requirement for wheel rim diameters exceeding 10 inches, nor do they provide the disqualifying characteristic of a full enclosure for the rider (operator) or passengers. Finally, while most states do not regard sidecars as separate vehicles, most would consider a trailer as such and may require a separate registration.
Mopeds - The same difficulties exist regarding the characteristics of a seat or saddle and steering handle bars as those noted for motorcycles. AAMVA also notes that some states do not require mopeds to have pedals, and that many do not have the brake horsepower requirement in their definition.
AAMVA further notes that states are currently struggling with how to register enclosed two and three-wheel vehicles, as well as how best to test the drivers on their ability to drive those vehicles. AAMVA is in the process of forming a working group to consider these issues, though some states would already consider enclosed vehicles to be motorcycles because they have no specific definition or requirements related to whether the vehicle is enclosed or not.
FHWA requested comment regarding the types of three-wheeled vehicles that are small and lightweight, with minimal chassis and body that may or may not be fully enclosed by doors and/or windows. AAMVA notes that if they are not enclosed, most states would currently consider these vehicles to be motorcycles for registration purposes. If so, these states most likely could not distinguish them from other motorcycles for purposes of reporting to FHWA.
FHWA’s request that the states report additional information on the relevant sections of the VIN of every motorcycle type vehicle registered with the states may create problems with state privacy laws related to the Driver’s Privacy Protection Act (depending on the specifics of those reporting requirements.) However, the process of extracting only certain characters from each motorcycle type VIN and reporting them could create a significant cost burden for the states. Finally, AAMVA notes that because motorcycle attributes contained in the VIN are less standardized than those for auto or truck type vehicles, we are not sure of the value of collection and reporting such information.
We appreciate the opportunity to submit comments, and if appropriate, we look forward to working with FHWA in this area. Should you have further questions or concerns related to these comments, please do not hesitate to contact me at your convenience.
Best Regards, Neil D. Schuster President & CEO
NOTE: Department of Transportation Federal Highway Administration [FHWA Docket No. FHWA-2010-0010]
Reclassification of Motorcycles (Two and Three Wheeled Vehicles) in the Guide to Reporting Highway Statistics http://edocket.access.gpo.gov/2010/2010-6361.htm
