[NAGDU] The Seeing Eye's comments on the Department of Transportation's Notice of Proposed Rule Making on Traveling by Air with Service Animals

[Jenine Stanley]

Absolutely agree with Buddy here. 

I know, having worked at a school, how the definition of “trainer” negatively effects the ability of the school to have its staff travel but if you think people fake disability now, just wait until you include “trainers” in the definition. We already have concerns about wayward puppy raisers claiming “trainer” status to gain access aside from what their programs tell them. 

I’d say that the schools and others, particularly the owner/trainers, band together and talk to the airlines about a program like Puppies in Flight that considers credentials or specific processes to vet, pardon the pun, actual trainers, either those working for organizations or the owner/trainer, who would be covered anyway in many cases as the animal is providing disability mitigation for that person during the flying experience. 

My somewhat sarcastic comment during the process of developing these proposed regs was that the schools would just have to hire a bunch of disabled people to ferry the dogs back and forth if needed as then the dog would be providing disability mitigation for that person. 

To be clear, the regs do allow for a trainer to take a dog to a disabled person, but it doesn’t go the other way, hence Puppies in Flight. If you’re not familiar with Puppies in Flight, it’s a program, started I think by US Air, to help schools in ADI move dogs around the country. They can help get retiring dogs back to the schools, puppies to raisers or from raisers, and dogs back to the school for evaluation or retraining without their person. Specially trained airline staff fly deadhead with the dogs. The program does have limitations, like blackout periods during the holidays but otherwise it’s a good program


> On Feb 21, 2020, at 12:06 AM, Buddy Brannan via NAGDU <nagdu at nfbnet.org> wrote:
> 
> I am, however, concerned by the following statement in the Seeing Eye’s comments:
> 
> If DOT is intent on defining "handler," The Seeing Eye requests that DOT expand the definition to include credentialed service animal trainers.
> 
> Given that there is no recognized credential for a service animal trainer, apart of course for certification by the specific training program, what does this actually mean? Moreover, what’s the real, substantive difference between a “credentialed” service dog trainer and an owner trainer? Seems to me that that’s opening up a whole ’nother can of worms, although I certainly understand the need for trainers to be able to transport dogs to or from a student or graduate. I can get behind defining the definition of “handler”, but let’s please be careful about what’s included, because that could come back to bite someone. Maybe me. 
> 
> 
> Buddy Brannan, KB5ELV - Erie, PA
> Email: buddy at brannan.name <mailto:buddy at brannan.name>
> Mobile: (814) 431-0962
> 
> 
> 
>> On Feb 20, 2020, at 11:50 PM, Buddy Brannan via NAGDU <nagdu at nfbnet.org <mailto:nagdu at nfbnet.org>> wrote:
>> 
>> Howdy y’all,
>> 
>> Yeah, I think Melissa’s link got a little bit mangled. Try this one.
>> https://www.seeingeye.org/graduates/comments-on-nprm-012220.html
>> 
>> 
>> Buddy Brannan, KB5ELV - Erie, PA
>> Email: buddy at brannan.name
>> Mobile: (814) 431-0962
>> 
>> 
>> 
>>> On Feb 20, 2020, at 4:39 PM, Melissa Allman via NAGDU <nagdu at nfbnet.org> wrote:
>>> 
>>> http://support.seeingeye.org/site/R?i=YDTp27sG-HPASZeoPFbXGA
>> 
>> 
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