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I've had multiple cases where I've been offered an upgrade from a compact to something giant and gas-guzzling. I'd rather have no upgrade than something like that, given that I have to pay for my own gas. I guess someone who's on a business trip where their gas is reimbursed anyway might look at it differently, though. (But to me it seemed like they were trying to "unload" a model that nobody wants on me, rather than "truly upgrading" me!)

An upgrade to a mini-SUV from even a compact can be common in some more-rural stations, such as JAC (Jackson Hole, Wyoming, the only commercial airport in the US located inside a national park!), because of the expectations of road conditions there (at least at some times of the year, but whatever vehicles they choose because of road conditions in winter are there to be rented in the summer too!).