<div dir="ltr"><div class="gmail_default" style="font-family:arial,sans-serif;font-size:small"><br></div><br><div class="gmail_quote"><div dir="ltr" class="gmail_attr">---------- Forwarded message ---------<br>From: <strong class="gmail_sendername" dir="auto">Al Elia via NAGDU</strong> <span dir="auto"><<a href="mailto:nagdu@nfbnet.org" target="_blank">nagdu@nfbnet.org</a>></span><br>Date: Wed, Jan 31, 2024 at 3:17 PM<br>Subject: [NAGDU] Petition to exempt guide dog users from DOT attestation form requirements<br>To: NAGDU Mailing List, the National Association of Guide Dog Users <<a href="mailto:nagdu@nfbnet.org" target="_blank">nagdu@nfbnet.org</a>><br>Cc: Al Elia <<a href="mailto:al.elia@aol.com" target="_blank">al.elia@aol.com</a>><br></div><br><br>Dear listmates,<br>
<br>
On Monday, the NFB filed a petition to exempt blind passengers from any <br>
requirements to complete attestation forms to travel by air with their <br>
guide dogs. Today that petition went up on <a href="http://regulations.gov" rel="noreferrer" target="_blank">regulations.gov</a> at <br>
<a href="https://www.regulations.gov/docket/FAA-2024-0286" rel="noreferrer" target="_blank">https://www.regulations.gov/docket/FAA-2024-0286</a><br>
<br>
We would appreciate comments in support of our petition. you may file <br>
comments at <a href="https://www.regulations.gov/document/FAA-2024-0286-0001" rel="noreferrer" target="_blank">https://www.regulations.gov/document/FAA-2024-0286-0001</a><br>
<br>
<br>
Here is the text of the petition itself for your convenience. The <br>
petition and supporting appendices can be downloaded from the <br>
<a href="http://regulations.gov" rel="noreferrer" target="_blank">regulations.gov</a> link above.<br>
<br>
<br>
January 29, 2024<br>
<br>
U.S. Department of Transportation<br>
Docket Operations<br>
West Building Ground Floor<br>
Room W12-140<br>
1200 New Jersey Avenue, SE.<br>
Washington, D.C. 20590<br>
<br>
Re: Petition for exemption from 14 C.F.R. §§ 382.27(b)(3), 75, and 79<br>
Submitted By: Elizabeth Schoen, Sherry Gomes, and Will Simpson, blind <br>
individuals; and the National Federation of the Blind (“NFB”), on <br>
behalf of its members, including Elizabeth Schoen, Sherry Gomes, and <br>
Will Simpson, representing a class of all blind individuals traveling in <br>
the United States.<br>
<br>
Pursuant to 49 C.F.R. § 5.3(a)(2) and 49 U.S.C. § 44701(f), <br>
Elizabeth Schoen, Sherry Gomes, and Will Simpson, who are all blind <br>
guide dog users, and the National Federation of the Blind, on behalf of <br>
its members, including Elizabeth Schoen, Sherry Gomes, and Will Simpson, <br>
petition the Federal Aviation Administration, through the Department of <br>
Transportation (“DOT”), for the following exemption on behalf of a <br>
class of all blind individuals on flights within, departing from, or <br>
arriving in the United States:<br>
Beginning one hundred and twenty days from the date of this petition and <br>
continuing indefinitely, all blind passengers seeking to travel by air <br>
with a guide dog service animal shall be exempt from the provisions of <br>
14 C.F.R. §§ 382.27(b)(3), 75, and 79(a)(4).<br>
This exemption is necessary as a reasonable modification, <br>
pursuant to Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § <br>
794, to ensure meaningful access to DOT-funded and regulated air travel <br>
by blind passengers who use guide dogs. Blind passengers who are unable <br>
to independently access the U.S. Department of Transportation Service <br>
Animal Air Transportation Form identified in 14 C.F.R. § 382.75(a) or <br>
the DOT Service Animal Relief Attestation Form identified in 14 C.F.R. <br>
§ 382.75(b) (collectively "DOT Forms"), either in print or electronic <br>
form, are being dissuaded from air travel and are even being denied <br>
passage on flights for which they have purchased tickets. They are <br>
suffering that discrimination because they are unable to complete and <br>
submit the DOT Forms independently in advance, and because the current <br>
regulations do not require air carriers to assist passengers like them <br>
in completing and submitting DOT forms in advance.<br>
Elizabeth Schoen, a blind college student, was not permitted to <br>
fly from Minneapolis to Boston in April 2023 because she was unable to <br>
complete and submit DOT Forms online. Ms. Schoen was obviously blind, <br>
and her guide dog was performing an obvious service of guiding her, but <br>
airline staff did not allow her to fly because she had not submitted DOT <br>
Forms in advance of her flight.<br>
Sherry Gomes has attempted to complete the DOT Forms, but was <br>
unable to do so without the assistance of a sighted person. Because she <br>
cannot independently complete the DOT Forms now required by airlines, <br>
she is afraid of being turned away or being otherwise mistreated at the <br>
airport because she uses a guide dog. She therefore no longer travels by <br>
air despite a desire to do so in order to visit friends and attend <br>
conferences.<br>
Will Simpson booked travel online in advance for Thanksgiving <br>
2023. During the reservation process, he was not informed as to how to <br>
indicate he would be traveling with his guide dog. After speaking with <br>
the air carrier’s staff by online chat, he was informed that his guide <br>
dog was known to the airline, and he would be able to travel. Instead, <br>
he was denied at the airport because he had not previously completed the <br>
DOT Form, and was only able to travel after arguing with the air <br>
carrier’s airport staff for over an hour.<br>
Reasons for and benefits of exemption<br>
This petition seeks an exemption from those sections of 14 C.F.R. <br>
Part 382 which allow air carriers to condition a passenger’s travel <br>
with a service animal on completion and submission of DOT Forms. The <br>
exemption is needed because, although certain blind travelers may not be <br>
able to complete the forms, or submit them in advance, the regulation <br>
does not require airlines to accommodate their disability. In fact, <br>
airlines are expressly permitted to refuse to provide such <br>
accommodations, as 14 C.F.R. §79(a)(4) specifically states that an <br>
airline “may deny transport to a service animal … [if t]he passenger <br>
with a disability seeking to travel with a service animal in the cabin <br>
of the aircraft does not provide completed current [DOT Forms] to the <br>
carrier when requested to do so.” Id. Petitioner Schoen was denied <br>
permission to fly, by the private airline relying on that regulation, <br>
because she did not complete the form on-line 48 hours prior to her <br>
flight, and the airline did not allow her to submit alternative <br>
verification that her service animal is a trained guide dog. This <br>
discriminatory denial of access is expressly permitted by the <br>
regulation, but it violates Section 504 of the Rehabilitation Act.<br>
Other sections of the ACAA regulations demonstrate DOT’s <br>
awareness that individuals with disabilities may need air carriers to <br>
provide them with assistance to ensure meaningful access to air carrier <br>
services offered through electronic technology. For example, air <br>
carriers “must assist prospective passengers who indicate that they <br>
are unable to use [the air carrier’s] Web site due to a disability and <br>
contact [the air carrier] through other channels (e.g., by telephone or <br>
at the ticket counter).” 14 C.F.R. § 382.43(c)(4). That requirement <br>
is in addition to a separate requirement that air carriers’ websites <br>
must be accessible. 14 C.F.R. §§ 382.43(c)(1)-(3). It goes on to <br>
require air carriers to disclose and allow booking of web-based discount <br>
fares through those other channels, and to waive any fees normally <br>
associated with use of those other channels. 14 C.F.R. §§ <br>
382.43(c)(4)(i)-(ii).<br>
The carrier requirements for provision and acceptance of the DOT <br>
Forms also demonstrate DOT’s understanding that some passengers with <br>
disabilities and service animals may not be able to use the electronic <br>
DOT Forms, notwithstanding their accessibility to other passengers. <br>
DOT’s regulations require carriers to make accessible electronic DOT <br>
Forms available on their websites, but also require them to provide <br>
paper copies of the forms upon request. 14 C.F.R. § 382.75(e). Those <br>
regulations similarly require airlines who demand advance submission of <br>
DOT Forms to not only accept them electronically, but also by hard copy. <br>
14 C.F.R. § 382.75(f). The requirement for paper copies to be sent and <br>
accepted by mail demonstrates DOT’s recognition that some persons with <br>
disabilities who use service animals may not have access to and the <br>
skills necessary to use technology to obtain and submit electronic DOT <br>
Forms. Despite this demonstrated awareness, and the understanding shown <br>
by the telephone-ticketing requirement that accessible technology is not <br>
a panacea, the DOT failed to require non-technological alternative <br>
access for blind passengers unable to complete the DOT Forms. That <br>
failure is inexcusable considering that guide dogs are the prototypical <br>
service animal.<br>
As discussed below, many blind guide-dog users cannot <br>
independently complete DOT Forms. Because air carriers are not required <br>
to assist such passengers in completing and submitting those forms, <br>
those blind passengers face significant obstacle that impede their <br>
access to air travel. The exemption sought herein will eliminate <br>
airlines’ ability to condition travel on submitting DOT Forms that <br>
those blind passengers cannot independently complete due to their <br>
blindness. By removing that obstacle, the exemption will ensure that all <br>
blind passengers who use guide dogs will have meaningful access to air <br>
travel.<br>
The exemption is necessary because the DOT cannot provide any other <br>
immediate remedy to address the barriers to air travel posed by the DOT <br>
Forms. The DOT is responsible for remedying those barriers because it <br>
alone bears responsibility for the DOT Forms and their shortcomings; and <br>
for failing to ensure air carriers’ provision of assistance to blind <br>
passengers in completing and submitting those forms where such <br>
assistance is necessary due to their disability.<br>
The public benefits when people with disabilities have meaningful <br>
access to air travel, and when the government does not impose barriers <br>
to such meaningful access for specific groups of persons with <br>
disabilities. The public also benefits when government agencies do not <br>
violate laws such as Section 504 of the Rehabilitation Act. The <br>
exemption is consistent with the Congressional charge that the <br>
“Federal Government play[] a leadership role in promoting … and in <br>
assisting States and providers of services in fulfilling the aspirations <br>
of such individuals with disabilities for … independent living…” <br>
29 U.S.C. § 701. Without the exemption, the regulation violates 29 <br>
U.S.C. § 794’s mandate that “[n]o otherwise qualified individual <br>
with a disability in the United States, as defined in section 705(20) of <br>
this title, shall, solely by reason of her or his disability, be <br>
excluded from the participation in, be denied the benefits of, or be <br>
subjected to discrimination under any program or activity receiving <br>
Federal financial assistance or under any program or activity conducted <br>
by any Executive agency…” (Id. Emphasis added.) The DOT actively <br>
regulates and provides funding to the airlines. By promulgating the <br>
regulation, DOT created and bears direct responsibility for its adverse <br>
impact on blind people who rely on guide dogs.<br>
There is no evidence to suggest that this exemption will negatively <br>
affect public safety. Guide dogs have a long record of safe travel, <br>
having been trained and used in the U.s. for more than ninety-five <br>
years. “History of Guide Dogs,” International Guide Dog Federation <br>
(available at <a href="https://www.igdf.org.uk/guide-dogs/history-of-guide-dogs/" rel="noreferrer" target="_blank">https://www.igdf.org.uk/guide-dogs/history-of-guide-dogs/</a> <br>
(last accessed Jan 24, 2024)). The NPRM supporting the regulation <br>
acknowledges that “dogs are the most common animal species used to <br>
assist individuals with their disabilities, both on and off aircraft, <br>
and that dogs have both the temperament and ability to do work and <br>
perform tasks while behaving appropriately in a public setting and while <br>
being surrounded by a large group of people.” (Traveling by Air With <br>
Service Animals, 85 FR 79742-01). Guide dogs receive structured <br>
socialization and behavior training not only by professional trainers as <br>
part of their several months of guide training (See “Standard 5: Dog <br>
Training and Behaviour,” Standards, International Guide Dog <br>
Federation, October 5, 2023 (available on request from <br>
<a href="mailto:enquiries@igdf.org.uk" target="_blank">enquiries@igdf.org.uk</a>)), but also by their volunteer puppy-raisers <br>
during the year leading up to that training. See, E.g., “Puppy Raising <br>
Manual,” Guide Dogs for the Blind (available at <br>
<a href="https://www.guidedogs.com/uploads/files/Puppy-Raising-Manual/Puppy-Raising-Manual-COMBINED.pdf" rel="noreferrer" target="_blank">https://www.guidedogs.com/uploads/files/Puppy-Raising-Manual/Puppy-Raising-Manual-COMBINED.pdf</a>).<br>
Likewise, concerns about “fake” service animals don’t apply to <br>
guide dogs. The DOT has never received a complaint that a passenger <br>
fraudulently represented themself as a blind person using a guide dog, <br>
nor has it received an assertion by any airline that a passenger has <br>
fraudulently completed DOT Forms indicating as Such. An individual is <br>
unlikely to attempt to pass off a pet or emotional support animal as a <br>
guide dog, as opposed to passing it off as another type of service <br>
animal for a less-obvious disability. Were they to make such an attempt, <br>
it would be readily apparent that the dog is not actually guiding the <br>
passenger, or that the passenger is not blind, or both.<br>
Finally, there are an estimated 500,000 working service animals <br>
of any type in the United States. See <br>
<a href="https://share.america.gov/service-dogs-save-lives/" rel="noreferrer" target="_blank">https://share.america.gov/service-dogs-save-lives/</a>. According to the <br>
International Guide Dog Federation, a member organization of guide dog <br>
training programs, there are only between 20,000 and 23,000 guide dogs <br>
in service worldwide at any given time. See <br>
<a href="https://www.igdf.org.uk/about-us/facts-and-figures/" rel="noreferrer" target="_blank">https://www.igdf.org.uk/about-us/facts-and-figures/</a>. Of those, only an <br>
estimated 10,000 are in use as working guide dogs in the United States. <br>
See, <a href="https://www.guidingeyes.org/guide-dogs-101/" rel="noreferrer" target="_blank">https://www.guidingeyes.org/guide-dogs-101/</a>. As those estimated <br>
10,000 guide dogs represent a mere two percent (2%) of the service <br>
animals in the United States, the regulatory requirements related to DOT <br>
Forms will still apply to ninety-eight percent of service animals and <br>
their users once this exemption is granted.<br>
Fundamental barriers to the DOT Forms<br>
The DOT Forms were intended to be accessible to passengers with <br>
disabilities, including blind passengers. However, as a practical matter <br>
the DOT Forms are only accessible to blind passengers who have access to <br>
and skills to use both necessary technology and the internet. This is <br>
because, the regulations only require carriers to make accessible <br>
electronic DOT Forms available on their websites and to accept completed <br>
forms electronically. Since paper is inaccessible to blind passengers <br>
absent the assistance of carrier staff, and since there is no provision <br>
requiring airlines to provide such assistance in person or by telephone, <br>
only the website offers them the possibility of access to the forms, and <br>
only electronic submission offers them the opportunity to access and <br>
submit forms in advance. These both require internet access, and both <br>
require access to and the skills to use the technology necessary to read <br>
and complete the DOT Forms. That technology is not available to all <br>
blind passengers.<br>
“Fillable” PDF forms such as the DOT Forms can only be <br>
completed with the aid of screen reading software on personal computers <br>
running Microsoft’s Windows or Apple’s macOS operating systems. See <br>
Declaration of Karl Belanger, attached as Appendix A. While it is <br>
possible for a blind person to read accessible PDF documents – <br>
including the DOT Forms – on other types of devices using screen <br>
reading software, it is not possible for a blind person to independently <br>
enter information on PDF documents and forms using screen reading <br>
software on mobile devices, tablets, or ChromeBooks, whether those <br>
devices are made by Apple, Google, Samsung, Amazon, or another <br>
manufacturer. Id. This is because manufacturers and developers have not <br>
yet built the capability to enter information on PDFs non-visually using <br>
screen reading software when using those devices. This is true even if <br>
the fillable PDF forms are otherwise accessible and can be completed <br>
non-visually using a personal computer running Windows or macOS. Id. <br>
Obviously, a blind person cannot independently obtain electronic DOT <br>
Forms from DOT or carrier websites without internet access. They can <br>
neither independently mark up a PDF using visual marking tools, nor <br>
independently complete paper DOT Forms by manually writing on them. As <br>
previously explained, the only technology that currently offers them the <br>
possibility to independently complete and submit DOT Forms is a personal <br>
computer. Courts have held that being able to access a governmental <br>
program or service independently is essential to meaningful access under <br>
the Rehabilitation Act. Nat’l Fed. Of the Blind v. Lamone, 813 F.3d <br>
494 (4th Cir. 2016). According to data from the latest American <br>
Community Survey (“ACS”) by the U.S. Census, only 56.1% of blind <br>
Americans have access to both a computer and the internet at home. See <br>
Declaration of Marlie Elia, attached as Appendix C. Accordingly, at <br>
least 43.9% of blind Americans entirely lack meaningful access to the <br>
DOT Forms. Id.<br>
This is not a speculative concern. As the following data shows, a <br>
large percentage of blind guide dog users currently experience barriers <br>
to using the DOT Forms, even if they have access to the internet. This <br>
data demonstrates the need for the exemption sought in this petition.<br>
Survey of Blind Guide Dog Users, and Extrapolation to Total U.S. Guide <br>
Dog-Using Population<br>
The National Association of guide Dog Users ("NAGDU"), a division <br>
of the NFB dedicated to advocacy regarding the rights and <br>
responsibilities of guide dog use, conducted an online survey from June <br>
through August 2023. See, Declaration of Raul Gallegos, attached hereto <br>
as Appendix B. That survey, in which 103 respondents participated, <br>
provides insight into how blind guide dog users experience air travel <br>
and what technology and comfort level they possess for finding and <br>
attempting to complete the DOT Forms. Id.<br>
It must be said at the outset that the survey undercounts blind <br>
persons who do not use technology to access the internet, as nearly all <br>
respondents said they did. This makes sense given that the survey was <br>
conducted online. Nevertheless, nearly four percent of respondents do <br>
not use technology to access electronic documents such as PDFs at all. <br>
This and other survey data reflect that even blind individuals, like Mr. <br>
Simpson and Mses. Schoen and Gomes, who might otherwise use the <br>
internet, nonetheless face technology barriers that prevent them from <br>
accessing the kind of electronic documents currently required to fly <br>
with their guide dogs.<br>
Despite its small sample size, the NAGDU survey comports with the <br>
estimates of the much larger ACS. The ACS data indicates that <br>
approximately 73.5% of blind people have access to the internet. <br>
Appendix C, Exh. 1. The NAGDU survey data indicates that, of those who <br>
do use the internet to access electronic documents like the DOT Forms, <br>
approximately 77.6% use a macOS or MS-Windows computer to access PDFs. <br>
Appendix B, Exh. 1. Combining those two indications yields an estimated <br>
57% of blind people who have access to both the internet and a personal <br>
computer, which comports with the ACS 56.1% estimate of the same. The <br>
NAGDU data shows that 22.4% of blind people who use the internet to <br>
access electronic documents can only<br>
do so using technology that currently affords them no way to <br>
independently complete fillable PDF forms such as the DOT Forms. Id.<br>
Beyond the absolute barriers currently presented by mobile and <br>
other non-macOS/MS-Windows technology, respondents encountered <br>
additional barriers regarding the DOT Forms that demonstrate the need <br>
for an alternative such as carrier assistance. For example, 29.4% were <br>
unable to identify what information the forms require a passenger to <br>
provide, 52% were unable to independently complete them, and 5.9% were <br>
unable to open them at all. Id. In fact, only 42.2% of respondents were <br>
able to independently fill out DOT Forms. Id.<br>
<br>
<br>
As to their air travel experiences, 34.3% of respondents have <br>
actually “experienced difficulty flying with a guide dog, such as <br>
being harassed by airline staff or being denied a flight due to not <br>
following airline pre-flight procedures for bringing a service animal," <br>
and 4.9% of respondents, Have never used a guide dog and are hesitant to <br>
do so due to the requirements for flying with a guide dog. Id.<br>
As discussed above, there are approximately 10,000 working guide <br>
dogs in use in the United States. See, <br>
<a href="https://www.guidingeyes.org/guide-dogs-101/" rel="noreferrer" target="_blank">https://www.guidingeyes.org/guide-dogs-101/</a>. Based on the ACS, only <br>
73.5% have internet access. The NAGDU survey indicates that of those, <br>
only 42.2% are able to independently complete DOT Forms. That means that <br>
69% of guide dog users in the U.S. are currently unable to independently <br>
access the DOT Forms; or six thousand nine hundred American guide dog <br>
users who lack meaningful access to the DOT Forms, and to air travel, <br>
because of their disability. DOT failed to ensure that blind passengers <br>
who use guide dogs would have such meaningful access, despite having <br>
demonstrated elsewhere that it understood the need and means to so <br>
ensure. As shown above, the petition should be granted.<br>
Jurisdiction of exemption<br>
This exemption will only apply within the jurisdiction of the <br>
United States. It will therefore only apply outside of the United States <br>
where a flight departs from or arrives in the United States.<br>
Summary for federal register<br>
The provisions of 14 C.F.R. §§ 382.27(b)(3), 75, and 79(a)(4) shall <br>
not apply to any blind passenger seeking to travel by air with a guide <br>
dog service animal. This means that no air carrier may require such a <br>
blind passenger to complete or provide forms as set forth in 14 C.F.R. <br>
§ 382.75(a) or (b), nor may an air carrier condition transport of such <br>
a guide dog service animal on the provision of any such forms.<br>
<br>
Respectfully submitted,<br>
<br>
s/ Albert Elia <br>
Albert Elia D.C. Bar No. 1032028<br>
Civil Rights Education and Enforcement Center<br>
1245 East Colfax Avenue<br>
Suite 400<br>
Denver, CO 80218<br>
303-757-7901<br>
<a href="mailto:aelia@creeclaw.org" target="_blank">aelia@creeclaw.org</a><br>
<br>
s/ Cynthia L. Rice <br>
Cynthia L. Rice<br>
Civil Rights Education and<br>
Enforcement Center<br>
131 Stuart Street<br>
Suite 400<br>
San Francisco, CA 94105<br>
303-551-9389<br>
<a href="mailto:crice@creeclaw.org" target="_blank">crice@creeclaw.org</a><br>
Attorneys for Elizabeth Schoen, Sherry Gomes, Will Simpson, and NFB<br>
<br>
<br>
CERTIFICATION<br>
I, Mark Riccobono, in my individual capacity and as the President and <br>
authorized representative of National Federation of the Blind, have not <br>
in any manner knowingly and willfully falsified, concealed or failed to <br>
disclose any material fact or made any false, fictitious, or fraudulent <br>
statement or knowingly used any documents which contain such statements <br>
in connection with the preparation, filing or prosecution of this <br>
petition. I understand that an individual who is found to have violated <br>
the provisions of 18 U.S.C. section 1001 shall be fined or imprisoned <br>
not more than five years, or both.<br>
<br>
MARK RICCOBONO<br>
_______________________________________________<br>
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</div><br clear="all"><div><br></div><span class="gmail_signature_prefix">-- </span><br><div dir="ltr" class="gmail_signature" data-smartmail="gmail_signature"><div dir="ltr"><div dir="ltr"><div dir="ltr"><div><i><font face="garamond, serif" size="4">Debbie Malone</font></i></div><div><div style="color:rgb(34,34,34)"><p class="MsoNormal" style="background-image:initial;background-position:initial;background-repeat:initial"><i><span style="font-family:Arial,sans-serif">National Federation of
the Blind of Massachusetts</span></i><span style="font-family:Arial,sans-serif"></span></p>
<p class="MsoNormal" style="background-image:initial;background-position:initial;background-repeat:initial"><i><span style="font-family:Arial,sans-serif">Affiliate Second Vice
President</span></i><span style="font-family:Arial,sans-serif"></span></p>
<p class="MsoNormal" style="background-image:initial;background-position:initial;background-repeat:initial"><i><span style="font-family:Arial,sans-serif">At-Large Chapter
President</span></i><span style="font-size:12pt;font-family:Arial,sans-serif"></span></p><p class="MsoNormal" style="background-image:initial;background-position:initial;background-repeat:initial"><i><span style="font-family:Arial,sans-serif">National Federation of the Blind, National Writers Division Vice President</span></i></p></div></div><div><font face="comic sans ms, sans-serif"><i><a href="https://inclusioneducation.com/" target="_blank">InclusionEducation.com</a></i></font><br></div><div><a href="https://www.amazon.com/~/e/B07RVCRR5R" target="_blank">Amazon Author Page</a></div><div><br></div></div></div></div></div></div>