In the Matter of Mars, Inc. and VCA Inc., File No. 171-0057 #00007

Submission Number:
Shannon Sullivan
Initiative Name:
In the Matter of Mars, Inc. and VCA Inc., File No. 171-0057
I practice about 1 hour north of Sacramento in California. There are three emergency hospitals/specialty centers within 30 miles of me. Of these two are owned by VCA and the third is proposed to be sold to VCA. Likewise in Sacramento, Banfield and VCA have a disproportionate market share and allowing the proposed VCA/Mars merger would be devastating to pet owners and private practitioners. We are already feeling the effect on our bottom line of increased regulation, increased wages, increased supply/drug and equipment costs. The VCA/Mars merger would result in unfair advantage in the market especially in light of pet food, laboratory and imaging arms of Mars. It is my deepest hope that the Mars/VCA merger is evaluated on the basis not just of hospital market share but also the degree of lateral integration that the merger would effect. In my mind the closest corollary I can imagine is the old coal mining town structure in which the company owned the mine, owned the major retail stores in town, owned the housing all at once. The VCA/Mars merger is not just about hospitals competing it is an attempt to unfairly influence a number of critical upstream processes that directly feed into the cost of providing and acquiring veterinary care thereby obtaining undue influence on the veterinary medical care market.