Submission Number: 00007
Received: 11/29/2012 9:15:07 PM
State: New York
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of Hertz Global Holdings, Inc., File No. 101-0137
Attachments: No Attachments
Dear Sir or Madame,
I understand that Hertz was recently allowed to purchase
Dollar/Thrifty, on condition of divesting their discount Advantage
brand, and divesting some Dollar/Thrifty locations at large airports.
While it might be assumed this would increase competition, in some
instances it actually would not. This is because corporate stores that do one-ways would be replaced with franchises that do not.
Ex, If Dollar/Thrifty corporate stores in, say the NYC airports, were
accepting a FL driveout, midsize for $1/day beats Hertz's $5/day for a
compact. However, if an independent licensee takes over those
airports, and a different operator runs each FL station, or all the FL
stations, the fleet is no longer interchangeable nationwide, and Hertz
becomes the cheapest option. In fact, there'd be less reason for Hertz
to stick with the $5/day lowest price point, since Avis and National
tend to match each other, starting at $19.95/day.
Hopefully this feedback is useful.