Thrifty Car Rental 2006 Annual Report Download - page 22

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 nonrenewal of franchises.
Other Matters
Certain states previously made vehicle owners (including vehicle rental companies) vicariously liable for
the actions of any person lawfully driving an owned vehicle, regardless of fault. Until August 10, 2005,
when a change in the vicarious liability law was imposed, some of these states, primarily New York, did
not limit this liability. With the passage of the federal "Highway Bill", unlimited vicarious liability for vehicle
rental and leasing companies has been removed, thus, limiting exposure to state minimum financial
responsibility amounts. 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 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.
Nevertheless, considering the nature and scope of Dollar’s and Thrifty’s businesses, it is possible that
regulatory compliance problems could be encountered in the future.
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 10 and lease 128 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 also may 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 presently are investigating or remediating soil or groundwater
contamination. Based on currently available information, the Company does not believe that the costs
associated with environmental investigation or remediation will be material. However, additional
contamination could be identified or occur in the future.
The use of automobiles and other vehicles is subject to various governmental requirements designed to
limit environmental damage, including that caused by emissions and noise. Generally, these
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