[NAGDU] Changes to the definition of Service Animal under the ACAA

[Jenine Stanley]

Thank you for posting these minutes. 

I serve on the ACCESS Committee along with Mr. Diggs. I am representing GDF and other guide and service dog schools. 

I would be happy to give anyone information about what is being proposed and why. 

Let me start by explaining the current ACAA definition of service animal. This definition includes animals that simply provide assistance through their presence with no disability training requirements. these are called Emotional Support Animals (ESAs). Technically all animals under the ACAA must have some level of ability to behave in public but the reality is that it’s hard to police and to avoid people like the woman with the chicken, described on this list, who was very forceful about her *rights*, airline staff tend to ignore things. 

Under the current ACAA definition of service animal , there are 3 sets of animals that can fly, free of charge, as accommodations to someone’s disability. Traditional service animals, guide, hearing, mobility and other types of animals trained specifically to mitigate an aspect of a disability, as well as having public access/exposure training, are allowed to accompany passengers with no requirement of documentation or prior notice. 

People who work with Psychiatric Service Animals, (PSAs) animals with specific disability mitigation training to address mental health related disabilities and with public access/exposure training,  must provide a letter including a diagnosis from the DSM4/5, on the stationary of a qualified mental health professional no less than 48 hours prior to flight. There are more specifics about this letter in the ACAA. 

ESA owners must also provide such a letter with the same information, stating that the animal is necessary. 

Unfortunately, people trying to avoid the pet fees or just not understanding the rules, and yes, not wanting to disclose their mental health-related disabilities to their existing health care providers, can go on line and find any number of doctors or organizations that will write the requisite letters on their behalf. There are also people who will buy vests and ID cards on line to avoid any of this and just call their animal a “service animal” meaning that it has some disability mitigation other than for a mental health related disability. 

The system is broken. This negotiated regulation process was convened to try to fix it, or at least come up with some new definition that wouldn’t break it even further. In another post I will detail what is being proposed and why.