FTC to Host Public Workshop Examining the U.S. Auto Distribution System Workshop Will Explore Competition, State Regulations, and Emerging Trends in the Industry, Project No. P131202
Thank you for the opportunity to comment. I have owned a Tesla Model S since February 2013. It is the best car I've ever owned for the price - and that says more about the true competition Tesla has brought to the U.S., indeed world, automobile industry than anything else I can say. Before Tesla arrived, the U.S. auto industry "competed" on superficialities - the technology in their cars and trust was pretty much the same and they competed instead on superficial option choices and by spending a lot on marketing and through temporarily cutting prices through sales (although as everyone knows the price "cuts" were not "real" in the sense that Consumer Reports made it clear that one could always get a "bottom line" price if oneknew how to go about it). Tesla competes instead by building cars/SUVs with new truly cutting edge technology - they are electric, get NHTSA's highest crash ratings of any vehicle, are far more energy efficient than ICE cars, receive over-the-air updates, have access to a free highway charging network (Tesla is the only car manufacturer to have this), have a very well thought out and user friendly computer interface to control all car functions, and are on the cutting and repidly-developing edge of autonomous driving technology, among other things. Tesla also does not advertise to speak of and (to my knowledge) does not periodically "cut" prices to have "sales". Now that Tesla has arrived, every major car company is scrambling to catch up to offer electric cars to compete with Tesla. If that isn't competition in the REAL sense of the word, I don't know what is. Thus, the suggestion that Tesla's direct-sale model restricts competition is contracdicted by the plain facts. The auto dealer network is interested only in one thing - holding onto their grip of being the "middle man" so they can charge consumers an extra fee to sell cars. The auto dealer fee (which Tesla does not have) serves primarily one function - to increae the price of an ICE car. It certainly doen't make servicing a car easier. I've had nothing but excellent experiences with Tesla's service centers - during the few times I've needed service, which incidentally has never been for major issues, since all of the servide issues I've had have been for very minor issues. I also understand (but the FTC would know better) that Tesla is not the only car company using a direct sales model now - even some of the more traditional car companies, like Volvo, are considering or may in fact be using direct sales to sell cars. The "independent dealer" network model for selling cars is an anachronism - it was born in the last century to serve a function that is no longer irreplaceable. If auto companies want to continue to use it, that's fine - that's what competition is all about. Choices. But, what the dealer network lobby shouldn't do is limit other innovative carmakers from using OTHER options to sell cars, like a direct sale model. This is nothing more than a freedom of choice issue. If Tesla is in fact LESS competitive because it's using a direct-sale model, then it will go out of business. That fact makes the FTC's choice easy Again, I appreciate the opportunity to comment.