Having said that, Tesla still has a very short history with limited numbers of vehicles on the road in comparison to other automakers. Special thanks to Peter for taking the time to meet with me! In the fall of , Peter bought a used Tesla Model S with rear wheel drive. Peter purchased the car directly from Tesla website and so it was a Tesla certified car. The car was delivered with 23, km 14, miles on it.
Whilst an odometer is used to record distance units can vary, usually between miles and kilometersa mileometer specifically records only in miles. The Telegraph. Warner, two odometerr from Beloit, Wisconsin, introduced their patented Auto-meter. As a result, quality and overall reliability has dramatically improved. It was Model a odometer a purely mechanical device but, in most modern vehicles, it is now electronic. Maintenance Model a odometer Please note that this was the 17,th Model S coming off of the factory line. The equivalent used to record kilometers is sometimes referred to as a "kilometreometer". Luxury vehicles often have multiple trip Data model example.
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In addition, as addressed below, any electronic odometer disclosure system must provide adequate means for verifying the identity of transferors and odmoeter. Revise the authority odometter to read as follows:. You may submit comments to the docket number identified in the heading of this document by any of the following methods:. I had a large doe cross full speed 20' in front of me. Upon successful completion of the transaction, the seller would mail the paper title to the State for Mldel. Taking of Marine Mammals documents in the last year. The Start Printed Page purchasing dealer would subsequently sign on to the system and review the vehicle's identifying information, including the odometer disclosure statement made by the selling dealer, and either accept or reject the transaction. I had Vehicle transactions cross State boundaries and the need for various State systems to interact must be considered. To authenticate the identity of the participants, Virginia's petition stated that a unique personal identification number PIN and a unique customer number that would Model a odometer be physically mailed to the individual would be used in conjunction with the customer's date of birth DOB to allow creation of an electronic odometer disclosure statement and signature. For each revolution a pin on the axle engaged a tooth cogwheel thus turning it one complete revolution per mile. Under the odometeg established by the Paperwork Odomeeter Act of PRAa person is not required to respond to a collection of information by a Federal agency unless the collection Model a odometer a valid OMB Transexual huge tits number. In connection with the transfer of ownership of a motor vehicle in which more than Game idea for teen person is a transferor, only one transferor need Modek the disclosure.
An odometer or odograph   is an instrument used for measuring the distance traveled by a vehicle, such as a bicycle or car.
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- The Public Inspection page on FederalRegister.
- An odometer or odograph   is an instrument used for measuring the distance traveled by a vehicle, such as a bicycle or car.
Gemmingen has already covered , km , miles according to two images shared on July The Model S P85 one of the oldest versions is reportedly running on its second battery pack. That's a remarkable amount of miles for any car and few gasoline-engined cars would go that far without an engine replacement.
What's even more impressive is that someone actually drives this much and choose a Tesla to do so. There may be other high-mileage Teslas out there, but their mileage has not been reported on the leaderboard, so we can't officially include them in this highest milage list.
And if you take a look below, you'll see that several Tesla Model 3s are beginning to rack up quite the miles too. By : Mark Kane. And the 1,, km mark will likely be reached later this year. Federal EV Tax Credit. Tesla Model S. Sign In or Sign Up.
NHTSA requests comments on the benefits and drawbacks of this proposal as well as other ideas to address this challenge while maintaining adequate safeguards of accurate disclosures and a paper-trail. NHTSA requests comments on what standards should be used for scanning and maintaining the documents including whether the scan must be in color, be made at a minimum resolution and if so, what required minimum resolution should be , or preserve the security features of the original to ensure that fraud or alteration could be detected, should it occur. First, only a State or State-authorized entity can create the new official document. NHTSA further proposes that the electronic copy of the physical document be retained for a minimum of five years, in an order that Start Printed Page permits systematic retrieval, and in a format that cannot be altered and that indicates any attempts to alter it. Your comments must be written and in English. The disclosures would not be made on a title but on a form described as a Secure Odometer Disclosure. In , in the course of the recodification of various laws pertaining to the Department of Transportation, the Cost Savings Act, as amended by TIMA, was repealed.
Model a odometer. Go to a specific date
Under Florida's proposal a seller with a vehicle having an electronic title wishing to sell the car would visit a tag office with the buyer.
After providing adequate identification to the tag agent, the buyer and seller would sign, in the presence of the tag agent, a secure reassignment form transferring ownership and disclosing the odometer reading. A title would then be issued in the buyer's name and stored electronically, or the buyer could choose to have the title printed as a physical document. For transactions involving dealers, Florida proposed that a seller with e-title would bring the vehicle to a dealership.
The seller and dealer would complete a secure reassignment form with odometer disclosure. When the dealer sold the vehicle to another buyer, the dealer and buyer would complete another secure reassignment form with odometer disclosure. The dealer would take both of the secure reassignment forms to a tag agency. The vehicle title would then be transferred to the buyer and the buyer would have the option to obtain a paper title or have Florida's Department of Transportation hold the title electronically.
Under Florida's proposal, the lessor of a leased vehicle would hold an e-title. When the lease ends, the lessee would bring the vehicle to a dealership. The lessee would sign an odometer disclosure statement on a secure physical document. The lessor would then sign a secure physical power of attorney to the dealer authorizing the dealer to execute the odometer disclosure. The dealer would then sign a physical secure reassignment form agreeing with the odometer disclosure.
When the dealer sold the vehicle to another buyer, the dealer would take the various physical documents bill of sale, reassignment document, and power of attorney to the tag agency, where the title would be transferred to the buyer. The buyer would then have the option of obtaining a new paper title or having the Florida Department of Transportation hold the vehicle title electronically.
Florida's request was granted for electronic transactions involving transfers between private parties but was denied for transactions involving dealers and leased vehicles. Among other things, NHTSA's final determination observed that transactions involving dealers relied on a number of odometer disclosures being made on documents other than the title itself. This, in the Agency's view, was inconsistent with TIMA's command that disclosures be made on the title and not on a separate document.
Further, the Florida scheme for dealer transactions would result in new registrations being issued after submission of a disclosure statement made on a physical reassignment document rather than on the title itself, thereby violating the requirement that a vehicle may only be registered if the new owner submits a title containing the odometer disclosure statement. Because of the proposed system's reliance on tag agents as the only point of data entry, completion of a transaction and execution of the required disclosure statements required that the disclosures be made on a number of documents, none of which were the actual title.
These documents also did not meet other content and security requirements. Moreover, the use of a power of attorney in an instance where the lessor would have access to the title, was viewed by the Agency as inconsistent with the narrow set of circumstances under which such a power of attorney could be used under TIMA.
The New York petition sought to convert the State's existing paper process for dealer transactions to an electronic process in which an authorized dealership user would sign on to the State's planned system and enter the vehicle's identifying information. The vehicle's odometer reading, disclosed on the title in the case of a consumer trading in or selling a vehicle to the dealer, would be recorded in the system by the dealer.
Access to the system itself would occur only at dealerships by specific dealer employees whose identity would be verified by State issued credentials. If that dealer sold a vehicle to another licensed New York dealer, the selling dealer would sign on to the proposed electronic system and enter current vehicle information, including the current odometer reading, as well as seller and purchaser information.
The Start Printed Page purchasing dealer would subsequently sign on to the system and review the vehicle's identifying information, including the odometer disclosure statement made by the selling dealer, and either accept or reject the transaction.
If the purchasing dealer accepted the transaction it would be considered complete. The original pre-dealer title still in the prior owner's name would be surrendered to the purchasing dealer at the time of sale. Subsequent transfers between licensed New York dealers would be recorded in the same manner. The history of the vehicle's identifying information entered into the system at each transfer would be maintained on the system. Under the New York proposal, when a vehicle owned by a New York dealer is sold to a retail purchaser, salvage dealer, out-of-state buyer or other non-New York dealer purchaser, the selling dealer would access the vehicle information on the system.
The selling dealer would enter current vehicle information, including the current odometer reading, and would enter seller and purchaser information. The purchaser would then review the information, including the odometer statement, on the draft receipt displayed on the computer screen. If the purchaser agrees with the odometer statement and other information, the authorized dealer representative would save the data in the system and then print a two-part sales receipt.
Both parties would then sign the odometer disclosure statement printed on each of the two parts of the receipt. The dealer would retain the dealer part of the receipt for its files, while the purchaser would be given the purchaser's copy of the receipt along with the original title acquired by the dealer when it purchased the vehicle. NHTSA's initial determination denied the New York petition because it used a non-secure receipt for odometer disclosure in transfers between New York dealers and out-of-state buyers and was therefore inconsistent with Federal odometer law.
The result of this change was that a consumer purchasing a vehicle from a dealer would then receive the original title and odometer statement executed by the owner who sold the vehicle to the dealer and the secure MV form with an odometer disclosure.
In addition, the mileage disclosed at the time of the sale to the dealer and the mileage disclosed at the time the dealer sold the vehicle to the subsequent retail purchaser would be recorded in New York's system and available for viewing through a web portal.
The Agency's final determination, 77 FR Aug. NHTSA found that the employment of the secure State issued and numbered MV form, in conjunction with the odometer disclosure on the original seller's title and the recording of these disclosures in New York's electronic system, met the purposes of TIMA.
The Arizona proposal was limited to transactions involving licensed Arizona dealers and did not encompass interstate transactions. Under this proposal, dealers would electronically scan and upload documents to the State. The State would retain electronic files in a document management system, and dealers would be required to retain hard copies of the documents.
The disclosures would not be made on a title but on a form described as a Secure Odometer Disclosure. This form would be completed and signed by hand and submitted to Arizona along with other documents after being scanned. The petition appears to propose that the title would not be among the documents submitted to Arizona, and it may be that this procedure would be followed if the seller's title is an electronic title.
If the dealer sells the vehicle, that dealer would again scan and electronically submit a Secure Odometer Disclosure, but not the title, to Arizona after selling the vehicle.
The dealer would retain the original Secure Odometer Disclosure forms for the retention periods specified by Federal and Arizona law. In instances where a dealer sought to sell a vehicle that had been purchased from an owner with a paper title, Arizona also proposed that the vehicle would be resold by a dealer using the paper title from the transferor. It appears, based on this description and the requirements of Arizona law that a dealer's name shall be recorded on a title certificate as transferee or purchaser and that a title include space for dealer reassignment information, that the dealer would make an odometer disclosure on the paper title at the time it resells the vehicle.
However, the petition also specifies that if the dealer applies for a new title in the name of the vehicle purchaser, the dealer and purchaser would complete a Secure Odometer Disclosure form.
The dealer would then scan and electronically submit a title application, the paper title, the Secure Odometer Disclosure form, and supporting documents to Arizona. The dealer would retain the original documents including the original paper title for the retention periods specified by Federal and Arizona law.
According to the petition, a new title would be sent to the buyer if there is no lien on the vehicle. If there is a lien, both the lien and the title would be maintained as electronic records by the Arizona Department of Transportation. The petition did not, in NHTSA's view, set forth the motor vehicle disclosure requirements in effect in the State or adequately demonstrate that the proposal was consistent with the purposes of the Motor Vehicle Information and Cost Savings Act.
In regard to the latter, the agency found that making disclosures on documents other than the title, the proposed use of non-secure forms, the failure to address record keeping requirements, and the potential for alterations posed by the use of scanned documents were all inconsistent with the purposes of TIMA.
NHTSA's experience in processing State petitions for alternative electronic odometer disclosure schemes illustrates a number of concerns that remain relevant for the purposes of this rulemaking. First and foremost, any electronic odometer disclosure system must be conceived with a full appreciation of the importance of following the command found in TIMA that odometer disclosures must be made on the title itself, or the electronic equivalent of that title, and not, except for a very limited number of exceptions, on any other document.
In particular, an electronic odometer disclosure system should minimize or eliminate odometer disclosures made on physical documents instead of promoting the use of such documents as some proposals Start Printed Page examined by NHTSA have done. Similarly, an electronic odometer disclosure system may not rely on a method of transmitting secure paper documents if that method does not preserve the security features now present in physical titles, reassignments, and powers of attorney.
A low resolution scan of such a document is not secure and such a scan may not reveal forgeries or alterations. In addition, as addressed below, any electronic odometer disclosure system must provide adequate means for verifying the identity of transferors and transferees. In the absence of such verification, unauthorized and inaccurate disclosures could easily be entered into State systems by imposters, defeating the purposes of the Cost Savings Act and enhancements established in TIMA and the subsequent amendments.
Electronic title and odometer disclosure systems must also foreclose the possibility that a seemingly valid physical paper title and an electronic title may co-exist.
While States are under no obligation to implement electronic odometer disclosure systems that accommodate transactions involving leased vehicles, any system that proposes to do so must employ measures that meet the existing regulatory requirements without employing physical forms such as a power of attorney that are not authorized under agency regulations.
Finally, all electronic odometer disclosure systems must be designed not to impede interstate vehicle sales while providing consumers with protection against odometer fraud. Unless and until electronic odometer disclosure is implemented in all States, Territories, and the District of Columbia, secure paper titles or their equivalent will be needed for the purposes of making odometer disclosures in interstate transactions. See 79 FR Feb.
While the authority EPA was operating under is different from NHTSA's current authority, and the existing system differed from the current odometer disclosure system, NHTSA believes there are lessons to be learned from EPA's experience transitioning from a paper to electronic environment. The EPA proposal envisioned the agency setting minimum standards for an e-manifest system and various private entities stepping forward to develop and make available such systems.
Others criticized the rigor of the standards proposed which set a higher bar than existed for paper documents. Still others noted that such detailed requirements could frustrate technology in an area which was constantly changing. Nevertheless, we are mindful of the comments EPA received. Vehicle transactions cross State boundaries and the need for various State systems to interact must be considered. Further, both traditional paper-based and electronic systems are likely to exist in neighboring States for some time and must facilitate interstate transactions while providing protection against odometer fraud.
The MAP mandate to permit electronic odometer disclosures could be frustrated by requirements that set an unnecessarily higher bar than currently exists for paper documents. However, NHTSA believes that achieving the objectives of the statute—to ensure that consumers receive valid representations of the actual vehicle mileage at the time of transfer and to detect, prevent, and aid in prosecuting odometer fraud—some aspects of the specific disclosure requirements may need to differ for traditional and electronic systems.
It is also neither helpful to the public nor wise to create rules that NHTSA must regularly amend to adapt to technological changes. The overall purpose of the odometer disclosure provisions of the Cost Savings Act, as amended, is to protect consumers by assuring that they receive valid representations of a vehicle's actual mileage at the time of transfer.
The statutory scheme and the current regulations adopted by NHTSA aim to achieve these overall purposes. In developing the current proposal for electronic odometer disclosures pursuant to MAP, NHTSA desires a regulation that continues to achieve these purposes without imposing overly burdensome requirements that are not necessary to achieve these purposes in an electronic environment.
That is, electronic disclosures must be made accurately by the actual parties to the transaction to protect consumers and provide assurances that a transferee receives a valid representation of a vehicle's actual mileage at the time of transfer. In addition, electronic disclosure schemes must have retention requirements to create a secure and reliable electronic trail to facilitate detection and prosecution of odometer fraud.
Unique issues the agency considered were the ability of different State electronic systems to share data, and the security of that information sharing, as well as the ability to issue secure paper documents for use in States which do not choose to adopt electronic disclosure requirements.
An additional issue considered by the agency was the possibility that, if NHTSA were to adopt only minimum requirements necessary to achieve the above stated purposes, States that voluntarily chose to permit electronic odometer disclosures could do so in ways which could eventually create enough variation to hinder on-going efforts among the States to develop a national system for electronic titling of motor vehicles.
However, NHTSA determined that its authority under MAP was intended only to facilitate the change to electronic odometer disclosures, not to impose additional requirements for odometer disclosures. NHTSA requests comments, however, on whether it should go further than proposed in this notice in order to prevent, or limit, variation among the various State systems. As noted earlier, NHTSA believes that meeting the objectives of the statute will require some variation in the requirements for traditional and electronic systems.
Therefore we are proposing to amend NHTSA is proposing to strike the regulatory text in section NHTSA requests comments on whether the following new definitions are appropriate and properly identify the items and actions intended. Electronic Document. This addition is necessary to provide clarity for the requirements and procedures applicable to these documents, as opposed to documents in paper format.
Physical Document. This addition is necessary to provide clarity for the requirements and procedures applicable to these documents, as opposed to documents in electronic format. Sign or Signature. This addition is necessary to clarify the actions and requirements that qualify as a signature or the signing of a document in the different contexts of physical and electronic disclosures.
Further, electronic records of contractual agreements are capable of verification through methods other than written words, and may include sounds, other symbols, or processes. See 15 U. One issue NHTSA considered was the electronic equivalent of the existing requirements for physical signatures on odometer disclosures and how to securely authenticate an electronic signature.
The publication defines four levels of assurance, Levels 1 to 4, in terms of the consequences of authentication errors and misuse of credentials, with Level 1 being the lowest assurance level, and Level 4 as the highest. Based on the level, different levels of authentication are recommended to help ensure the security of the information.
As discussed below, NHTSA has made a preliminary determination that at least NIST Level 3 verification should be required, both to prevent the potential harm of fraudulent disclosures and to aid in their prosecution. Attachment A to the OMB memorandum sets out six potential Start Printed Page impact categories, and then, depending on whether the impact is low, moderate, or high, assigns a NIST assurance level. The Attachment does not provide specific guidance for how to assign an overall assurance level if potential impact categories fall in different levels.
The impact categories are:. The purpose of odometer fraud is to induce consumers to pay more for a used vehicle than they would if they knew the accurate mileage.
For an individual consumer, it is important that the value of the vehicle reasonably match the price agreed to, and paid, based upon the information available to the consumer and provided by the seller. In addition, odometer fraud is often committed by the same individual s or entities multiple times, resulting in high dollar amounts of damages. State electronic title and odometer disclosure systems will also contain sensitive personal information that could be subject to unauthorized release if the system were not sufficiently secure.
Last, odometer fraud is a criminal offense that victimizes innocent consumers. NHTSA and other enforcement agencies use odometer disclosure documents to prove these criminal violations. Therefore, after reviewing this document, NHTSA has made a preliminary decision that a high level of assurance in the accuracy of the identity of the person making an odometer disclosure is necessary, and therefore the appropriate level of security for odometer disclosures is Level 3 according to the NIST guidelines.
NHTSA is therefore proposing that any State which allows electronic odometer disclosures require security protocols at this level or higher. These attributes include verification of the name associated with the user, issuance of a credential to the user through a separate channel such as postal mail, text message or telephone call directed at an address or number confirmed through examination of different independent databases and use of that credential to gain access to the Level 3 system.
For example, a person wishing to make odometer disclosures electronically without having to appear in person at a State motor vehicle agency would need to have a valid Government ID number and a financial institution or utility account number that could be confirmed through examining records containing those numbers.
The State entity providing the e-title and odometer disclosure service would then check the information provided by the individual and confirm that the name, date of birth, and other personal information in the examined records are consistent and sufficient to identify a unique individual. The State entity would then issue a credential by postal mail or some other means that would direct the credential to the proper person. The issued credential would then be employed by the user to obtain access to the electronic odometer and title system.
As outlined in the NIST guidelines, other methods may be employed to attain Level 3 authentication but the important principle, in NHTSA's view, is that Level 3 requires multi-factor identification of an individual applicant who, once their identity has been verified, is provided with a unique credential in order to access the system. However, this also will require the use of computers by all parties for all transfers in electronic title States.
NHTSA requests comments on the appropriate NIST level and if specific identification verification s should be required, and further requests comments on how such a system should be implemented, including whether dealers should be required to provide secure computing services to transferors and transferees and what security measures should be mandatory for such services. NHTSA also considered the existing requirements that various parties provide copies of documents as part of the odometer disclosure process, and what would qualify as an equivalent in an electronic environment.
For example, section Under the current system, the transferee may apply for a new title for the vehicle, and generally, a State will not title a vehicle without an odometer disclosure statement that contains the signatures of both the transferor and the transferee.
However, the State does not usually verify that a copy of the document was returned to the transferor or that the transferor retained it. For this reason, NHTSA is concerned about imposing any requirement in the electronic environment that would be more restrictive than these current requirements. NHTSA therefore proposes to specify only that the requirement to provide a document is satisfied by electronically transmitting the document, provided that the State allows the parties to the transaction access to the completed disclosure statements.
As discussed previously, one purpose of the signature requirement is to aid in the prosecution of odometer fraud. Further, currently any power of attorney forms and all documents used to reassign title must be issued by the State and be created using a secure process. It is central to the integrity and efficacy of the motor vehicle titling systems and Start Printed Page odometer disclosure laws that the authenticity and security of title documents, at a minimum, be maintained at their current levels in moving to electronic disclosure and titling systems.
Currently, investigators are able to examine physical documents and observe indicators of tampering. Unlike paper documents, however, alterations to electronic documents are much more difficult to detect from a visual inspection. Further, while electronic documents and transactions provide opportunity to enhance security, as with physical documents, these systems are still susceptible to manipulation and attacks.
Such requirements are necessary to protect both the financial interests of motor vehicle owner's and potential buyers, as well as to aid law enforcement in preventing, detecting, and prosecuting odometer fraud. NHTSA contemplated proposing specific minimum requirements for system security, but has preliminarily determined that it would be counter-productive, and thus inappropriate, to do so. NHTSA based this decision on the knowledge that the rulemaking process is typically slow, while developments in technology are fast and frequent.
While proactive changes to enhance cyber security are constantly evolving and improving, cyber-attacks and efforts to undermine the security of electronic data systems are also changing rapidly and frequently. The rulemaking process would not be able to keep pace with these technological changes and it is foreseeable that, if NHTSA imposed specific system requirements, the specific requirements could become obsolete, yet remain the requirements while a new rulemaking is undertaken.
Alternatively, to the extent that rulemaking by NHTSA would be able to keep up with the dynamic technological landscape, such constant revisions to the regulations would result in an ever-changing set of specific requirements for States to adhere to.
Further, the potential risks to property interests and commerce presented by insecure vehicle titling and odometer disclosure systems are obvious, since it is critical that the owners, buyers, and sellers of motor vehicles have certainty in their ownership status and avoid being defrauded in the fundamental details about the vehicle they own or are buying.
By NHTSA's adoption of more general minimum requirements, any State that choses to adopt an electronic disclosure system will be able to select the specific system requirements it believes are most appropriate, while ensuring information security for motor vehicle owners, buyers, and law enforcement. While NHTSA's expectation is that any State implementing an electronic disclosure system would take these various risks into account and establish appropriate safeguards, NHTSA nonetheless requests comments on whether it should establish minimum specific security requirements in this rulemaking and, if so, what requirements would be appropriate.
NHTSA requests comment on whether requirements should be included for the hardware used in an electronic odometer system to protect the system from threats which could disrupt the electronic records, either from natural or manmade sources and, if so, what requirements should be included in a final rule.
NHTSA considered the issue of what odometer information disclosures and procedures should be required for paper and electronic disclosures, and what appropriate modifications can and should be made for electronic disclosures. In an effort to track the electronic disclosure requirements to the existing requirements, NHTSA makes the following proposals regarding the odometer disclosures and procedures.
The requirements currently apply to all title transfers and, as a practical matter, this results in no change in the disclosure requirements whether made on a physical document or electronically. As currently written, this requirement necessarily implies the ability to affix information onto a document. The requirement for making electronic disclosures on an electronic form incorporated into the electronic title means that paper disclosures would become the rare exception when electronic disclosure and titling is available.
Further, the electronic systems would need to be designed to contain or otherwise embed the electronic odometer disclosure in the electronic title. Finally, for electronic transfers where the transferor is the individual in whose name the vehicle is titled, reassignment documents would not be necessary.
NHTSA seeks comments on the proposal that disclosures be made on an electronic form incorporated into the electronic title. This proposed requirement is intended to ensure that the information is provided in a size and location that is clearly viewable and readable to individuals making electronic transfers, and that transferors do not unintentionally bypass this information without having an opportunity to review it.
NHTSA envisions that the acknowledgement would typically be a box for the party Start Printed Page to click acknowledging having seen and understood the information, not unlike the boxes often seen on Web sites and computer programs today acknowledging service limits or contractual rights prior to gaining access to content or services. NHTSA proposes to not extend the printed name requirement to electronic disclosures because the purpose of the printed name is to provide hand writing exemplars for use in fraud investigations and prosecutions.
However, at present, NHTSA is not aware of electronic systems that capture handwriting with the level of clarity and precision that exists when applying hand-writing to paper.
As a result, unlike physical handwriting exemplars, NHTSA does not currently believe that electronic handwriting exemplars would provide the intended investigatory and prosecution tools to law enforcement. The requirement that the transferee print his or her name on the disclosure therefore need not be extended to electronic disclosures. In contrast, it remains important for both parties to the transaction to have access to a record showing the disclosure that was made, and it is appropriate to extend the current requirement that the transferee provide a copy of the disclosure to the transferor to electronic transfers.
In an electronic disclosure jurisdiction, the parties would not have physical control of the disclosure documents and the responsibility to provide copies of the disclosure must fall to the operator s of the disclosure system. These records not only provide assurance to the parties of what information was relied upon in the transaction, but could also aid law enforcement in investigations and prosecutions.
NHTSA requests comments on the proposal to not extend the printed name requirement to electronic disclosures, including technologies that provide comparable electronic hand-writing exemplars as paper document exemplars, and on the proposal to require that any electronic system be capable of providing the transferor and transferee with a copy or record of the disclosure made. NHTSA has considered how to handle odometer disclosure for a vehicle that has not been titled or for which the title does not contain a space for the information required.
Under the existing paper disclosure systems, in such instances the parties execute the odometer disclosure as a separate paper document.
This system would not make sense in an electronic disclosure system since the first time a title was obtained for any given vehicle the odometer disclosure would be incorporated into that electronic title at the time of creation and no electronic title system would be created that did not provide space for the required information.
The option relating to insufficient space on the title is a holdover from when odometer disclosures were first required on the title and jurisdictions needed time to bring titles into conformity with the new regulation. That concern is not applicable here since electronic disclosure systems will be designed and implemented using the requirements established in this rule.
Similarly, no special provision is needed for providing the information in the first instance of titling in an electronic disclosure jurisdiction, since any electronic system will include the execution of an electronic disclosure that is incorporated into the electronic title upon creation. NHTSA requests comments on the proposal to limit the current separate document disclosures for first title issuance and when the title does not contain sufficient space for the disclosure requirements to paper title jurisdictions, and requiring disclosures for first title issuance to be conducted within the electronic title system in electronic disclosure jurisdictions.
NHTSA has considered the differences between disclosures made on physical documents and those made on electronic documents and preliminarily determined that additional requirements are necessary to ensure the accuracy and authenticity of electronic disclosures. NHTSA has also considered the complications that could arise, including competing claims of vehicle ownership, if both paper and electronic titles co-exist as an official form of title issued within a jurisdiction.
This proposed requirement adds as an explicit condition for electronic disclosures an implicit reality of disclosures on physical documents.
Disclosures on physical documents provide some method for detection of alterations or attempts to alter the document.
While techniques for altering the physical documents evolve over time, they nonetheless leave an indicator, however hard to detect, of that alteration or attempt. Electronic documents thus present a different challenge since many documents are easily altered, and some of the techniques used can be difficult to trace.
A system that prevents alteration is critical for consumer confidence in the disclosure system and information relating to the alteration of disclosure documents is critical to the enforcement of the odometer disclosure laws and in preventing odometer fraud. NHTSA requests comments on this proposed additional requirement for electronic disclosures and what, if any, more specific requirements would be appropriate to ensure that electronic records are not altered and indicate any attempts to alter them.
Currently, each person signs their own name to a physical document when completing an odometer disclosure and is uniquely identified as an individual. Or at least that is presumed for non-fraudulent transactions. Similarly, in an electronic disclosure system, each individual person will need to be uniquely identified by their own unique electronic signature.
This is necessary to protect the financial interests of vehicle owners and purchasers, providing certainty that the vehicle title remains with the lawful owner and that odometer disclosures are made by the appropriate individuals, who can be located, if needed. As a practical matter, this is particularly necessary for transactions involving individuals who complete portions of disclosures on behalf of others, like an employer.
For example, when a vehicle owner seeks to trade in a car at a car dealership in an electronic disclosure jurisdiction the parties would no longer need to provide power of attorney and reassignment documents for the dealer to use in selling the vehicle at a later date, but instead would simply transfer title from the vehicle owner to the car dealer and make the odometer disclosure on the electronic form which is incorporated into the title. This will require an individual at a car dealership to enter information into the electronic disclosure system on behalf of the business or entity on whose behalf that individual is operating.
NHTSA has considered the importance of maintaining confidence that the parties are who they claim to be for ownership and law enforcement purposes. NHTSA has also considered challenges created in fraud investigation and prosecution if both the individual and business, or entity, are not identified by the code or signature associated with an individual acting in this capacity to input data into the system.
NHTSA requests comments on this proposal. However, in an electronic system, in many cases there will not be any document to provide, and instead, information can be made available to the parties via the electronic system.
Moreover, part of the rationale for using an electronic disclosure and titling system is to reduce the amount of paper being used. It would defeat one of the purposes of electronic disclosure to require the printing and delivery of documentation at various stages. It could also add unnecessary complications to the electronic delivery of documentation if specific electronic delivery mechanisms were required.
NHTSA requests comments on the usefulness of this proposal. The continued use of physical documents to accomplish transfer of title or odometer disclosure in an electronic disclosure jurisdiction is strongly discouraged, as each different document presents a new opportunity for fraudulent activity to occur. However, to the extent that the continued use of physical documents is necessary in an electronic system, any physical documents used must comply with all requirements of this part.
In a written environment it is possible to determine which document has an original signature and, therefore, to distinguish original or official documents from copies. In addition, when a print copy is made of an electronic odometer disclosure, what should be done to specify whether the print document is now the official document or the electronic document remains the official document?
This issue could arise when a vehicle titled with an electronic odometer disclosure is moved to a State which either does not participate in electronic odometer disclosures or which has an electronic odometer system that cannot communicate directly with the system in the State in which the vehicle is currently titled. First, NHTSA is proposing that once an odometer disclosure is incorporated in the electronic title, the electronic title containing the disclosure is the official record of ownership and mileage.
The electronic disclosure does not continue as a record separate from the electronic title as that would be contrary to TIMA and would provide additional opportunity for fraud. If an electronic title containing an odometer disclosure must be converted to a paper document as the official document, NHTSA is proposing additional requirements. First, only a State or State-authorized entity can create the new official document. Second, the paper document must be set forth by means of a secure printing method as a physical, paper document.
As a practical matter, this may present certain logistical challenges, particularly for individuals in an electronic title State who seek to buy a new car, and trade-in their old car, in another State. This issue is discussed at greater length below regarding Power of Attorney, and NHTSA requests comments on how this logistical challenge can be avoided or mitigated. Third, the electronic record must be altered to clearly indicate that an official paper document has been issued, to whom, and the date of issuance.
This document could be used for persons who would like a paper copy but would not like the official document to be converted to a paper document. NHTSA requests comments on the benefits and drawbacks of such a record and whether the option of obtaining such a document should be required under the regulations. NHTSA further proposes that the electronic copy of the physical document be retained for a minimum of five years, in an order that Start Printed Page permits systematic retrieval, and in a format that cannot be altered and that indicates any attempts to alter it.
The five year retention requirement proposed in this paragraph matches the retention period of similar documentation held by dealers and distributors of motor vehicles and auction companies.
Finally, NHTSA is also proposing that any paper documents scanned or copied electronically for storage in an electronic system be converted through a process providing a minimum resolution of dots per inch dpi to ensure the preservation of security features during the conversion process. NHTSA requests comments on what standards should be used for scanning and maintaining the documents including whether the scan must be in color, be made at a minimum resolution and if so, what required minimum resolution should be , or preserve the security features of the original to ensure that fraud or alteration could be detected, should it occur.
These requirements are necessary as security and authenticity of disclosure information is fundamental to all types of disclosures within the odometer disclosure system. Otherwise, disclosures regarding leased vehicles would continue on physical documents. As with all other electronic disclosures, it is appropriate and necessary that individuals making the disclosure be provided with the notice of Federal law and possible penalties for providing false information.
NHTSA is therefore proposing to amend this requirement to include electronic copies or electronic documents as an acceptable form of record. Under both sections, records must be stored for five years in a manner and method so they are accessible to NHTSA investigators and other law enforcement personnel. The records must also be stored so they are difficult or impossible to modify. As previously discussed, unlike paper documents, alterations to electronic documents are much more difficult to detect from a visual inspection.
NHTSA requests comment on whether this requirement would be sufficient to allow law enforcement to detect altered documents.
NHTSA is proposing to modify the power of attorney provisions. In this way, the electronic title with the required odometer disclosure is equivalent to a lost title or a title held by a lienholder. Without this additional permitted use of power of attorney, the seller from an electronic title State cannot trade-in his old car and buy a new car in a paper title State unless the seller first remembers, and plans ahead, to obtain a printed title from the electronic title State before going car shopping.
For example, assume Mr. Smith lives in an e-title State but goes to a paper title State to trade-in his old car and buy a new car. He must either get his paper title first or there must be some means for him to make his odometer disclosure without a title.
Electronic title States will not likely be in a position to provide secure paper titles on demand. This means Mr. Smith cannot buy a new car unless he gets his electronic title printed as a physical title first. The agency believes this is unlikely to happen in many, if not most, instances. While the use of power of attorney provides an additional step in the transfer process, and thus another opportunity for fraud to occur, the agency believes as a practical matter that there must be some other way for a vehicle owner from an electronic title State to sell the vehicle in a paper title State without first obtaining a converted official paper title from the electronic title State.
However, power of attorney laws vary from State to State, so even with this modification there may still be States that retain paper title systems where vehicles registered in electronic title States could not be sold without the converted official paper title. NHTSA requests comments on the benefits and drawbacks of this proposal as well as other ideas to address this challenge while maintaining adequate safeguards of accurate disclosures and a paper-trail. NHTSA requests comments on whether power of attorney would be necessary in an electronic odometer system for intra-state transfers.
Therefore, NHTSA requests comments on whether odometer disclosure by power of attorney would be made on other than a paper document, i. Further, NHTSA has concerns that the validity of power of attorney may vary from State to State and the possible implications of that variability in interstate transactions and requests comment on this issue.
This typographical error in the regulation creates inconsistency within the reporting scheme. The average age of the United States vehicle fleet has been trending upward and recently reached NHTSA also requests comments on whether this exemption should be eliminated.
Your comments must be written and in English. To ensure that your comments are correctly filed in the Docket, please include the docket number of this document in your comments. Your comments must not be more than 15 pages long. We established this limit to encourage you to write your primary comments in a concise fashion. However, you may attach necessary supporting documents to your comments.
There is no limit on the length of the attachments. Follow the online instructions for submitting comments. Please note that pursuant to the Data Quality Act, in order for substantive data to be relied upon and used by the agency, it must meet the information quality standards set forth in the OMB and DOT Data Quality Act guidelines.
Accordingly, we encourage you to consult the guidelines in preparing your comments. If you wish Docket Management to notify you upon its receipt of your comments, enclose a self-addressed, stamped postcard in the envelope containing your comments. Upon receiving your comments, Docket Management will return the postcard by mail.
When you send a comment containing information claimed to be confidential business information, you should include a cover letter setting forth the information Start Printed Page specified in our confidential business information regulation. We will consider all comments that Docket Management receives before the close of business on the comment closing date indicated above under DATES.
To the extent possible, we will also consider comments that Docket Management receives after that date. If Docket Management receives a comment too late for us to consider in developing a final rule assuming that one is issued , we will consider that comment as an informal suggestion for future rulemaking action. The hours of the Docket are indicated above in the same location.
You may also see the comments on the Internet. Follow the online instructions for accessing the dockets. Please note that, even after the comment closing date, we will continue to file relevant information in the Docket as it becomes available.
Further, some people may submit late comments. Accordingly, we recommend that you periodically check the Docket for new material. We have considered the potential impact of this proposal under Executive Order , Executive Order , and the Department of Transportation's regulatory policies and procedures, and have determined that it is not significant.
This proposal amends existing requirements to allow States a new alternative means of complying with those requirements. It does not impose any new regulatory burdens. Therefore, this document was not reviewed by the Office of Management and Budget under E.
We have reviewed this rule for the purposes of the National Environmental Policy Act and determined that it would not have a significant impact on the quality of the human environment. Pursuant to the Regulatory Flexibility Act 5 U. No regulatory flexibility analysis is required if the head of an agency certifies the proposal would not have a significant economic impact on a substantial number of small entities. SBREFA amended the Regulatory Flexibility Act to require Federal agencies to provide a statement of the factual basis for certifying that a proposal would not have a significant economic impact on a substantial number of small entities.
The head of the agency has certified that the proposed rule would not have a significant economic impact on a substantial number of small entities. This proposal is only allowing States the option of an alternative means of complying with an existing requirement and therefore would not impose any new impact on any small entities. Executive Order requires agencies to determine the federalism implications of a proposed rule. The agency has determined that the proposed rule does not have sufficient federalism implications to warrant the preparation of a Federalism Assessment.
The proposed rule merely adds another option to the way States are allowed to process and issue existing odometer disclosure requirements, and does not alter the effect on the States of existing statutory or regulatory requirements. When promulgating a regulation, Executive Order specifically requires that the agency must make every reasonable effort to ensure that the regulation, as appropriate: 1 Specifies in clear language the preemptive effect; 2 specifies in clear language the effect on existing Federal law or regulation, including all provisions repealed, circumscribed, displaced, impaired, or modified; 3 provides a clear legal standard for affected conduct rather than a general standard, while promoting simplification and burden reduction; 4 specifies in clear language the retroactive effect; 5 specifies whether administrative proceedings are to be required before parties may file suit in court; 6 explicitly or implicitly defines key terms; and 7 addresses other important issues affecting clarity and general draftsmanship of regulations.
The preemptive effect of this proposal is discussed above in connection with Executive Order Odometers were first developed in the s for wagons and other horse-drawn vehicles in order to measure distances traveled. Daneben wird auch der grosse verborgene Wegweiser angezeiget und vermeldet. In , the French mathematician Blaise Pascal invented the pascaline. Though not an odometer, the pascaline utilized gears to compute measurements. Each gear contained 10 teeth.
The first gear advanced the next gear one position when moved one complete revolution, the same principle employed on modern mechanical odometers. Odometers were developed for ships in with the odometer invented by the Englishman Thomas Savery.
Benjamin Franklin , U. The Roadometer used two gears and was an early example of an odometer with pascaline-style gears in actual use. In , Curtis Hussey Veeder invented the Cyclometer. In Arthur P. Warner, two brothers from Beloit, Wisconsin, introduced their patented Auto-meter. The Auto-Meter used a magnet attached to a rotating shaft to induce a magnetic pull upon a thin metal disk.
Measuring this pull provided accurate measurements of both distance and speed information to automobile drivers in a single instrument. The new firm was renamed the Stewart-Warner Corporation. By , Stewart-Warner odometers and trip meters were standard equipment on the vast majority of automobiles and motorcycles manufactured in the United States.
By the early s, mechanical odometers would be phased out on cars from major manufacturers. Whilst an odometer is used to record distance units can vary, usually between miles and kilometers , a mileometer specifically records only in miles. The equivalent used to record kilometers is sometimes referred to as a "kilometreometer".
Most modern cars include a trip meter trip odometer. Unlike the odometer, a trip meter is reset at any point in a journey, making it possible to record the distance traveled in any particular journey or part of a journey. It was traditionally a purely mechanical device but, in most modern vehicles, it is now electronic. Luxury vehicles often have multiple trip meters. Most trip meters will show a maximum value of The trip meter may be used to record the distance traveled on each tank of fuel, making it very easy to accurately track the energy efficiency of the vehicle; another common use is resetting it to zero at each instruction in a sequence of driving directions, to be sure when one has arrived at the next turn.
This is done to make a car appear to have been driven less than it really has been, and thus increase its apparent market value. Most  new cars sold today use digital odometers that store the mileage in the vehicle's engine control module making it difficult but not impossible to manipulate the mileage electronically.
Older vehicles can be driven in reverse to subtract mileage, a property that provides the premise for a classic scene late in the comedy film Ferris Bueller's Day Off , but modern odometers add mileage driven in reverse to the total as if driven forward, thereby accurately reflecting the true total wear and tear on the vehicle. The resale value of a vehicle is often strongly influenced by the total distance shown on the odometer, yet odometers are inherently insecure because they are under the control of their owners.
Many jurisdictions have chosen to enact laws which penalize people who are found to commit odometer fraud. In the US and many other countries , vehicle mechanics are also required to keep records of the odometer any time a vehicle is serviced. Companies such as Carfax then use these data to help potential car buyers detect whether odometer rollback has occurred.
Most odometers work by counting wheel rotations and assume that the distance traveled is the number of wheel rotations times the tire circumference, which is a standard tire diameter times pi 3. If nonstandard or severely worn or underinflated tires are used then this will cause some error in the odometer. It is common for odometers to be off by several percent. From Wikipedia, the free encyclopedia. For other uses, see Odometer disambiguation. For a detailed list of the recorded distances by Alexander's bematists, see Bematist.
Main article: Odometer fraud. Retrieved Scientific American. Bibcode : SciAm. Archived from the original on The Horseless Age. Connecticut Humanities Council. The Globe and Mail. The Telegraph. Houses of the Oireachtas website. Part of a series of articles on cars. Safety Seating. Audio Automobile auxiliary power outlet Cup holder Car Phone. Category Commons Portal.
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Tesla Model 3 gets FM radio and trip odometer in new OTA update - SlashGear
Having said that, Tesla still has a very short history with limited numbers of vehicles on the road in comparison to other automakers. Special thanks to Peter for taking the time to meet with me! In the fall of , Peter bought a used Tesla Model S with rear wheel drive. Peter purchased the car directly from Tesla website and so it was a Tesla certified car. The car was delivered with 23, km 14, miles on it.
The warranty is , kilometres bumper to bumper. Today, Peter has just over , km , miles on it. Peter does a lot of highway driving due to his work. Each year, Peter estimates that he puts on around 45, km or 28, miles. Shortly after taking delivery of the vehicle, the battery had an issue. Consequently, Tesla replaced the battery AND the motor free of charge. In fall of , the new battery range was km or miles.
Internal Combustion Engines ICE vehicles with , km typically have had a significant amount of maintenance performed over their lifetime. For example, multiple oil changes, fluid changes, belts, pumps, spark plug replacements, etc.
However, Tesla is not immune from breakdowns. Please note that this was the 17,th Model S coming off of the factory line. In other words, one of the first cars Tesla produced. As a result, quality and overall reliability has dramatically improved. For example, replacing the battery after only 20, km is unusual. Since then the car has put on an additional , km and suffered very little degradation.
Having said that, Tesla has stood by the car as evidenced by much of the work performed through warranty. Thank you for reading my high mileage Tesla Model S maintenance post! In the meantime, please feel free to like, comment, share, and subscribe! Very interesting article! The ,km warranty is pretty good.
But does it cover the removal of protein stains in the rear seat upholstery? This is an important factor in any of my vehicle purchases. Your email address will not be published. Notify me of follow-up comments by email. Notify me of new posts by email. July 23, July 23, 1 Comment. Range and Battery Degradation Shortly after taking delivery of the vehicle, the battery had an issue.
Maintenance Issues Covered by Warranty Two weeks after purchase, the battery had an issue and was replaced. In addition, Tesla went ahead and all replaced the drive unit motor.
Replacement of 4 door handles. The wiring harness wore out, but has since been replaced with newer generation components. Replacement of Charge Port. Sunroof chattering when opening Front driver seat defective rail assembly New 12v battery 2x They tend to wear out every 2 years. Tail light seals factory seals let moisture in, so was replaced Steering rack bolts as part of a recall.
The charge port has been replaced 3 times. The first time was under warranty. Perhaps this is partially due to extreme Canadian winters cold temperatures, road salt. In addition, the car is driven a lot and needs to be charged frequently.
Therefore, leading to more wear and tear. Intermediate steering shaft worn out. Broken rear passenger swing arm. On set number 4. Peter mentioned that he tends to buy inexpensive tires.
Consequently, overall tire quality is probably a bit below average and wears out faster. Moreover, Peter also has a heavy foot. Having said that, a Model S weighs approximately kg or lbs. I assume the weight also contributes to wearing out tires faster than on a lighter vehicle. Brakes have NOT been replaced. In fact, by the time most cars hit , km, brakes may have been replaced 3 times.
Maintenance Conclusion Please note that this was the 17,th Model S coming off of the factory line. Post navigation Tesla Supercharger Station in Saskatchewan. Related Articles. August 15, August 15, No Comments. Tesla Supercharger Station in Saskatchewan.
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