Thrifty Car Rental 2011 Annual Report Download - page 19

or capping the rates, of loss damage waivers could result in the loss of this revenue for Dollar, Thrifty
and their franchisees.
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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