dissenting.
I dissent and would affirm based on the reasons set forth in the Commonwealth Court Opinion. The Majority premises its opinion on: 1) the Commonwealth Court’s disregard of the sound principle of limited judicial review of administrative agency decisions; and 2) public policy considerations. In concluding these vehicles are not “new vehicles” as defined in 63 Pa.S.A. § 818.10(12), the Commonwealth Court applied the proper three prong test and did not exceed its permissible scope of review.
I) Standard of Review.
The Majority first contends that the Commonwealth Court departed from the “sound principle” that “an administrative agency’s expert interpretation of a statute for which it has enforcement responsibility is entitled to great deference and will not be reversed unless clearly erroneous.” Majority Op. at 357, citing, Mormak v. Unemployment Compensation Bd. of Rev., 135 Pa.Commw. 232, 237, 579 A.2d 1383, 1385-86 (1990).
*360[The] Commonwealth Court’s standard of review in an appeal from a decision of an administrative agency is limited to determining whether the agency’s adjudication is in violation of the constitutional rights of the appellant, an error of law has been made by the agency, or the agency’s findings of fact are not supported by substantial evidence. 2 Pa.C.S.A. § 704 (Purdon Supp. Pamphlet 1990); Commonwealth Commission on Charitable Organizations v. Association of Community Organizations for Reform Now, 502 Pa. 1, 468 A.2d 406 (1988).
Chester Extended Care Center v. Commonwealth, Dept. of Pub. Welfare, 526 Pa. 350, 355, 586 A.2d 379, 382 (1991) (emphasis added).
The Pennsylvania State Board of Vehicle Manufacturers, Dealers and Salespersons (“Board”) applied the two prong test adopted by the Majority. The Commonwealth Court determined that the Board, by ignoring the requirement that a >new vehicle must in fact be a new vehicle, erroneously concluded that the statute embodied a two prong test rather than a three prong test and committed an error of law. Therefore, in reversing the Board, the Commonwealth Court did not exceed its permissible scope of review.1
II) Intention of the General Assembly.
The Majority next argues that “the Board’s view on this matter is supported by cogent reasons and a sensible public policy.” Majority Op. at 357. The Majority points to the consequences of adopting the Commonwealth Court’s three prong test, highlighting “grey marketing” and the loss of consumer protection under Pennsylvania’s Automobile Lemon Law, 73 Pa.S.A. §§ 1951—1963. While a court may consider “the consequences of a particular interpretation,” such consid*361erations are only appropriate “[w]hen the words of the statute are not explicit.” 1 Pa.C.S.A. § 1921(c). By leaping directly to policy considerations and the resulting consequences of adopting the three prong test, the Majority disregards established principles of statutory construction.
A. Explicit Words.
“The object of all interpretation and construction of statutes is to ascertain and effectuate the intention of the General Assembly.” 1 Pa.C.S.A. § 1921(a); Commonwealth v. Lurie, 524 Pa. 56, 60, 569 A.2d 329, 331 (1990). “When the words of a statute are clear and free of all ambiguity, the letter of it is not to be disregarded under the pretext of pursuing its spirit.” Id. at § 1921(b); Walker v. Fennell, 426 Pa.Super. 469, 472, 627 A.2d 771, 773 (1993). Only “[w]hen the words of a statute are not explicit,” may a court ascertain the intention of the General Assembly by considering:
(1) The occasion and necessity for the statute.
(2) The circumstances under which it was enacted.
(3) The mischief to be remedied.
(4) The object to be obtained.
(5) The former law, if any, including other statutes upon the same or similar subjects.
(6) The consequences of a particular interpretation.
(7) The contemporaneous legislative history.
(8) Legislative and administrative interpretations of such statute.
1 Pa.C.S.A. § 1921(c) (emphasis added); Freeze v. Donegal Mutual Insurance Co., 412 Pa.Super. 305, 312, 603 A.2d 595, 598, appeal denied, 532 Pa. 656, 615 A.2d 1312 (1992).
“Words and phrases shall be construed according to rules of grammar and according to their common and approved usage.” 1 Pa.C.S.A. § 1903(a); Appeal of Hume Village, 51 Pa.Commw. 465, 468, 414 A.2d 768, 769-70 (1980); Township of Derry, Dauphin County v. Swartz, 21 Pa.Commw. 587, 589, 346 A.2d 853, 855 (1975). It is a presumption of statutory construction “[tjhat the General Assembly intends the entire *362statute to be effective and certain.” 1 Pa.C.S.A. § 1922(b); Jones v. W.C.A.B. (Midland-Ross Corp.), 148 Pa.Commw. 593, 597, 612 A.2d 570, 572 (1992), appeal denied, 533 Pa. 638, 621 A.2d 583 (1993). “Whenever possible, each word in a statutory provision is to be given meaning and not to be treated as surplusage.” In re Employees of Student Services, 495 Pa. 42, 52, 432 A.2d 189, 195 (1981); Habecker v. Nationwide Ins. Co., 299 Pa.Super. 463, 471, 445 A.2d 1222, 1226 (1982); Fumo v. Hafer, 155 Pa.Commw. 520, 525, 625 A.2d 733, 735 (1993).
The statute defines a new vehicle as “a new vehicle which has never been registered or titled in Pennsylvania or any other state on which a tax for education ... has not been paid prior to sale.” 63 Pa.S.A. § 818.10(12) (emphasis added). It clearly and unambiguously defines a new vehicle as a new vehicle. As the Commonwealth Court stated, “[t]he legislature could have chosen the words a vehicle or any vehicle but, rather, chose to include in its definition of a new vehicle that the vehicle must also be new.” Alpha Auto Sales v. Dept. of State, 149 Pa.Commw. 621, 626, 613 A.2d 679, 682 (1992) (emphasis in original). By adopting the two prong test, the Majority completely ignores the presence of the term “new,” treating it as mere surplusage. As a result, the Majority eliminates a definitional requirement and violates a principle of statutory construction.2
Because the word “new” is not technical and has not acquired a peculiar and appropriate meaning, it “shall be construed according to ... [its] common and approved usage.” 1 Pa.C.S.A. § 1903(a). Pennsylvania courts have generally used dictionaries to determine the common and approved usage of a term. See Patricca v. Zoning Bd. of Adjustment of City of Pittsburgh, 527 Pa. 267, 275, 590 A.2d 744, 748 (1991); In re Stout, 521 Pa. 571, 583-4, 559 A.2d 489, 495-6 (1989); Love v. City of Philadelphia, 518 Pa. 370, 374, 543 A.2d 531, 532 (1988); McIntyre v. Board of Supervisors of Shohola Township, 150 Pa.Commw. 15, 20, 614 A.2d 335, 337 (1992); Hitch-*363ings v. Pennsylvania State Ethics Comm’n., 147 Pa.Commw. 384, 607 A.2d 866 (1992); Tobin v. Radnor Township Bd. of Comm’rs., 142 Pa.Commw. 567, 582-3, 597 A.2d 1258, 1266 (1991).
Following sound principles of statutory construction, the Commonwealth Court referred to Webster’s Third New International Dictionary (“Webster’s”) to ascertain the common and approved usage of “new.” Webster’s defines “new” as “having existed or having been made but a short time: ... as opposed to old.” Alpha Auto Sales, 149 Pa.Commw. at 626, 613 A.2d at 682. The Commonwealth Court then applied this definition to the statute and concluded that the vehicles were in fact not “new.”
B. Factors indicating Legislative Intent.
Even if the words of the statute were not explicit, an examination of the factors listed in 1 Pa.C.S.A. § 1921(c) would still reveal the General Assembly intended a three prong test. Prior to 1984, when the present statute took effect, new vehicles were defined as:
[mjotor vehicles which have never been registered or titled in Pennsylvania or any other state and on which a tax for education ... has not been paid prior to such sale.
63 Pa.S.A. § 805(2)(xvi) (repealed January 1, 1984), quoted in D & B Auto Sales v. Commonwealth, Dept. of State, 29 Pa.Commw. 113, 116, 370 A.2d 428, 430 (1977). This statute established a two prong test defining a new vehicle as one: 1) that has never been registered or titled in Pennsylvania or any other state which imposes a sales tax; and 2) on which the sales tax has not been paid prior to sale to a consumer. Id. 29 Pa.Commw. at 118-9, 370 A.2d at 431.
Effective January 1, 1984, the definition of a “new vehicle” was amended to its present form. The only difference is that a new vehicle must now be a new vehicle and not just a “motor” vehicle. “A change in the language of a statute ordinarily indicates a change in legislative intent.” Masland v. Bachman, 473 Pa. 280, 289, 374 A.2d 517, 521-2 (1977). See *364also 1 Pa.C.S.A. § 1921(c)(5) (“intention of the General Assembly may be ascertained by considering ... the former law”). If the General Assembly did not wish to require a new vehicle to be “new,” it would not have added “new” to the definition. The additional requirement that a new vehicle be in fact a “new” vehicle and not just “a” vehicle or “any” vehicle exhibits a legislative intent to narrow the previous two prong definition. The majority’s two prong test ignores this clear manifestation of legislative intent. Prior to the statute’s amendment, courts applied the two prong test. D & B, 29 Pa. Commw. at 118-9, 370 A.2d at 430. Now, after the General Assembly specifically amended the statute to require that a new vehicle must also be “new,” the Majority applies the very same two prong test, oblivious to the addition of the newness requirement. Rather than confront the statute’s clear and unambiguous language or the obvious implications of the 1984 definitional change, the Majority resorts to tenuous policy considerations of potential consequences.
Before addressing the policy considerations on which the Majority relies, I would point out that these policy arguments focus on the implications of the Commonwealth Court’s decision itself, rather than on the legal analysis employed to reach that decision. In this dissent, I agree with the Commonwealth Court’s conclusion that the Board committed an error of law by applying a two prong test. I believe the General Assembly intended a three prong test. However, I do not necessarily agree with the Commonwealth Court’s application of the three prong test and its conclusion that these are not new vehicles.3
*365The Commonwealth Court applied Webster’s definition of “new” and concluded that the vehicles were in fact not “new vehicles.” The vehicles at issue are 1988 Yugos. Alpha Auto Sales acquired these vehicles in November and December of 1988. While under Webster’s definition, one might argue these vehicles had existed or had been made but a short time and therefore were new, I reiterate that I dissent from the Majority’s complete disregard of the newness requirement itself, and not necessarily from the Majority’s reversal of the Commonwealth Court decision and reinstatement of the Board’s order. Although the Majority focuses on the consequences of the Commonwealth Court’s decision and fails to reach the central issue of the proper legal analysis, I shall still address their policy arguments.
The Majority adopts the Board’s contentions that the Commonwealth Court decision would “open the door for a new ‘grey market.’” Majority Op. at 358. The grey market, which the Majority argues might lead to the “potential importation of vehicles that do not meet U.S. environmental and safety requirements,” does not pose any problem. There is nothing illegal about the grey market. Grey market automobiles are already legally imported into this country. Procedures exist by which the
importer of a noncomplying vehicle must post a bond with the Customs Service in an amount at least equal to the value of the vehicle to secure the completion of the required modifications. 19 C.F.R. §§ 12.73 and 12.80. When the importer has successfully modified the vehicle and demonstrated compliance with applicable safety and auto emission standards, the bonds are released.
Direct Automobile Imports Ass’n, Inc. v. Townsley, 804 F.2d 1408, 1409 (5th Cir.1986). Because the bond amount must at least equal the value of the imported vehicle, therefore tying up significant capital, it effectively acts as a barrier to the number of imported grey market vehicles. Affirming the *366Commonwealth Court decision would not increase grey market imports.
The Majority claims a “vehicle would be classified as used because it passed from one dealer’s inventory to another.” Majority Op. at 155. This is simply untrue. The vehicles here passed from the inventory of a new car dealer to that of a used car dealer. They were sold and the' warranties began to run. More occurred than just a mere shifting of inventory.
The Majority also contends that the Commonwealth Court’s decision would create “uncertainty as to the quality of trademarked goods,” eliminate “warranty protection to the consumer,” and cause purchasers of this type of vehicle to “lose the protection of Pennsylvania’s Automobile Lemon Law.” Majority Op. 155. However, the Commonwealth Court concluded that these are used vehicles. The warranties began to run. The Automobile Lemon Law does not apply to used vehicles and used car dealers. Furthermore, lack of warranty protection and uncertainty as to quality always exist when purchasing a used car.
Ill) Conclusion.
The Commonwealth Court correctly concluded that the Board committed an error of law when it applied an improper legal analysis. By focusing on the potential consequences of the Commonwealth Court decision rather than on the proper legal analysis, the Majority loses the forest for the trees. While these policy considerations are important, they should be considered in the context of applying the three prong legal test, and not as a means of skirting clear, explicit legislative intent.
This dissent obviously begs the question as to how to define “new.” While Webster’s definition is useful, it does not constitute the final word. I would suggest that in addition to considering the temporal connotations of “new,” we examine, among other factors, whether the manufacturer’s warranties have begun to run or have expired. However, on this issue I believe it would be appropriate to defer to the Board as the *367expert administrative agency charged with the execution and application of the Board of Vehicles Act so it can define “new” in a manner consistent with its policy concerns.
For all of the above reasons, I would remand to the Commonwealth Court with instructions to remand to the Board for further proceedings consistent with this dissent.
. The Commonwealth Court stated, "[t]he issue before this Court is whether the Board erred in concluding, as a matter of law, that the vehicles were new vehicles under Section 10(12) of the Act....” Alpha Auto Sales v. Dept. of State, 149 Pa.Commw. 621, 624, 613 A.2d 679, 681 (1992). Thus, contrary to the majority’s assertions, the Commonwealth Court did advance a cogent reason to justify the "departure from ... [the] principle of limited review.” Majority Op. at 155.
. Nowhere does the Majority explain its reasons for ignoring "new.” Rather, the Majority glosses over this omission by shifting the focus to policy considerations.
. The Commonwealth Court referred to Webster’s to define "new” as "having existed or having been made but a short time: ... as opposed to old,” Alpha Auto Sales, 149 Pa.Commw. at 626, 613 A.2d at 682, and concluded that "new” embodies some temporal element. This conclusion is further bolstered when one examines the definition of a "new motor vehicle” in the Automobile Lemon Law. 73 Pa.S.A. §§ 1951— 1963.
The Automobile Lemon Law, enacted only three months after the Board of Vehicles Act, begins its definition of a "new motor vehicle” with the requirement that a new motor vehicle be new and unused. Id. at § 1952. The presence of "unused” joined to "new” by "and” indicates a legislative intent to add a meaning not encompassed by *365“new.” Thus, it appears the legislature used “new” to encompass a temporal requirement, rather than a use requirement.