Dollar Rent A Car 2011 Annual Report Download - page 18

Franchising Regulation
As franchisors, Dollar and Thrifty are subject to federal, state and foreign laws regulating various aspects of franchise operations and sales. These laws
impose registration and disclosure requirements on franchisors in the offer and sale of franchises and, in certain states, also apply substantive standards to
the relationship between the franchisor and the franchisee, including those pertaining to default, termination and non-renewal of franchises.
Other Matters
Vehicle rental and leasing companies have insurance liability exposure for amounts up to each state’s minimum financial responsibility for the actions of any
person driving a company-owned vehicle. Vehicle rental companies are also subject to various federal, state and local consumer protection laws and
regulations including those relating to advertising and disclosure of charges to customers.
Dollar and Thrifty are subject to federal, state and local laws and regulations relating to taxing and licensing of vehicles, franchise sales, franchise
relationships, vehicle liability, used vehicle sales, insurance, telecommunications, vehicle rental transactions, environmental protection, privacy and labor
matters. The Company believes that Dollar’s and Thrifty’s practices and procedures are in substantial compliance with federal, state and local laws and is not
aware of any material expenditures necessary to meet legal or regulatory requirements.
Environmental Matters
The principal environmental regulatory requirements applicable to Dollar and Thrifty operations relate to the ownership, storage or use of petroleum products
such as gasoline, diesel fuel and new and used motor oil; the treatment or discharge of waste waters; and the generation, storage, transportation and off-site
treatment or disposal of waste materials. Dollar and Thrifty own 20, and lease 100, locations where petroleum products are stored in underground or above-
ground tanks. For owned and leased properties, Dollar and Thrifty have programs designed to maintain compliance with applicable technical and operational
requirements, including leak detection testing of underground storage tanks, and to provide financial assurance for remediation of spills or releases.
The historical and current uses of the Dollar and Thrifty facilities may have resulted in spills or releases of various hazardous materials or wastes or
petroleum products (“Hazardous Substances”) that now, or in the future, could require remediation. The Company may also be subject to requirements
related to remediation of Hazardous Substances that have been released into the environment at properties it owns or operates, or owned or operated in the past,
or at properties to which it sends, or has sent, Hazardous Substances for treatment or disposal. Such remediation requirements generally are imposed without
regard to fault and liability for any required environmental remediation can be substantial.
Dollar and Thrifty may be eligible for reimbursement or payment of remediation costs associated with releases from registered underground storage tanks in
states that have established funds to assist in the payment of such remediation costs. Subject to certain deductibles, the availability of funds, the compliance
status of the tanks and the nature of the release, these tank funds may be available to Dollar and Thrifty for use in remediating releases from their tank
systems.
At certain facilities, Dollar and Thrifty are investigating or remediating soil or groundwater contamination. Based on currently available information, the
Company does not believe that the costs associated with environmental investigations or remediation will be material.
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