[NAGDU] Notice of Proposed Rule-Making regarding service animals on airplanes

[piper foster]

The provisions of these proposed rules do not sound like they’re designed to protect the rights of those with disabilities, contrary to the assertion in the document, itself. Rather, it sounds like a policy to keep as many individuals with disabilities who travel with a service animal off the airlines, entirely. 
What, do we still make some people uncomfortable by our very presence among them? I’d almost think so, after reading the section about what Congress has directed be looked into as methods of “vetting” every type of service animal whose partner wishes to fly with them. Some of these are:
(1) photo identification for service animals;(2) training documentation;(3) medical documentation indication the tasks the animal performs to assist its user, and(4) whether more than one service animal should be permitted (per person).
Other considerations to be part of the new rules are things like requiring health and vaccination records for service animals, third-party proof of behavior training for service animals, and almost as if an afterthought, Congress directs the committee to ”consider the impact of additional requirements on passengers with disabilities traveling with service animals and ways to eliminate or mitigate those impacts.”
A final rule on service animals must be issued, under the Congressional directive, no later than March 22, 2020.
What I learned from this is that Congress has oversight of the FAA and thus controls the ultimate direction in which the ACAA will go. I fear the ability of owner-trainers to fly with their service animals may be nearing an end, because I’d also suspect the voices of certain large organizations like ADI will have a substantial impact on this rulemaking.
I hope I’m reading this all wrong, but I suspect I’m not. 
Piper

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