[NAGDU] Notice of Proposed Rule-Making regarding service animals on airplanes
cindyray at gmail.com
cindyray at gmail.com
Thu Jan 23 15:37:52 UTC 2020
Hi, Danielle,
I like what you have said here. These are all valid points. However, I do
take exception to one of them and wonder why you like this:
* restricting the number of service animals to two
Why do you think this is valid? Most often it wouldn't be an issue one way
or another, but let's say an NFB or ACB Convention ends and a lot of people
are getting on the same plane. This was truly something to consider in
Orlando when a huge number of folks were flying to Atlanta to make
connections. There could easily be many more dogs on the flights than two.
So would you want us to have to state that we have a dog, which of course is
probably not an issue anyway if these rules were passed? How would they
decide who would get to go on the flight? Would it be a lottery? I realize
this doesn't happen a lot, but I know there are certainly instances when it
could. The Washington Seminar comes to mind.
Thanks for your help on this. I really do like what you have written.
Cindy Lou Ray
cindyray at gmail.com
-----Original Message-----
From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Danielle Sykora via
NAGDU
Sent: Thursday, January 23, 2020 9:15 AM
To: NAGDU Mailing List, the National Association of Guide Dog Users
<nagdu at nfbnet.org>
Cc: Danielle Sykora <dsykora29 at gmail.com>
Subject: Re: [NAGDU] Notice of Proposed Rule-Making regarding service
animals on airplanes
Here is what I wrote on another discussion about this. I intend to polish
this and post an official comment soon.
Things I like
* No longer allowing ESAs (though I wouldn't be entirely opposed to
exploring regulating them separately and more strictly)
* Restricting service animals to dogs (though allowing miniature horses as
an exception on a case-by-case basis like in the ADA could be explored)
* classifying psychiatric service dogs as service dogs (which they are), not
lumping them together with ESAs
* restricting the number of service animals to two
things I don't like
* Having to check in an hour early. If this is in addition to the normal
time, this would mean checking in three hours early for domestic flights and
four hours early for international. That's forcing the service animal to go
an extra hour without relieving, and they are already having to go a long
time in some cases.
* Providing attestations of behavior. If someone wants to pretend their pet
is an SD, what is stopping them from simply lying on the form? There aren't
any consequences for doing so. Having the form filled out by a third party
will never be reliable, because who is a reliable third party? Vets may know
nothing about training and behavior, and there isn't any requirement for dog
trainers to be licenced. Owner trainers can't just show a program issued ID
card, and some service dog programs (yes even ADI certified ones) produce
some truly terrible dogs.
* Providing health records from a veterinarian. Getting an annual report
filled out would not tell you all that much about the dog. A dog could be
free of parasites today, but not next week. Anything that must be filled out
more often than annually would force handlers to pay an unnecessary fee for
an office visit at minimum. I'm also concerned that airlines will start
forcing people to give their dogs elective vaccinations. For example,
bordetella is optional and some owners and vets will titer for distemper,
but what if an airline decides these are now required?
* Size restrictions. If the dog is sprawled across the isle or taking up the
entire row, of course this is a problem. The most common breeds of service
dogs are Labs and Goldens though, so restricting large dogs would have a
huge impact on service dog handlers Essentially, that would restrict most
guide and mobility dogs. Learning how to tuck under seats is part of public
access training. I've seen 90 lb dogs that curl up tightly, and 30 lb dogs
that are allowed to stretch out in the isle.
* The assertion that employees should have no responsibilities at all.
If animals are not removed from airports for poor behavior, literally
nothing will solve the problem--no amount of paperwork will ever be the same
as proper training. I've seen countless horrifically behaved dogs in public
with multiple employees witnessing their behavior, but nothing is ever done.
If an employee ignores a dog lunging an growling at a person in the airport
and that dog proceeds to bite a flight attendant an hour later, that
employee is partially responsible.
I don't think it is unreasonable to ask for proof of rabies, because this is
a requirement for all dogs. It is also the only significant disease that
would be directly transferred from dog to human that is vaccinated against.
I wish this could be provided in a way that didn't require advanced notice
or additional burdens. Perhaps anyone traveling with a dog would be required
to show a rabies certificate before going through the security checkpoint or
something.
Danielle
On 1/23/20, Cindy Ray via NAGDU <nagdu at nfbnet.org> wrote:
> It was the year before as I recall. And another thing. (Tracy, this
> isn't about you.) I don't think any of us should ever write to this
> list and say "What is NAGDU going to do about this? Whether we are
> members of NAGDU or not, it is up to all of us to "do something about
> it." DGUI, NAGDU, and everybody who uses a dog or doesn't needs to do
> something about it. I don't want to see people posting to this list
> "What is NAGDU going to do about it." If we are in NAGDU we will want
> to support what NAGDU does; if we are not, we want to support what
> NAGDU does because it will make a difference to all of us in the end.
> Cindy Lou Ray
> cindyray at gmail.com
>
>
> -----Original Message-----
> From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Tracy Carcione via
> NAGDU
> Sent: Thursday, January 23, 2020 7:59 AM
> To: 'NAGDU Mailing List, the National Association of Guide Dog Users'
> <nagdu at nfbnet.org>
> Cc: Tracy Carcione <carcione at access.net>
> Subject: Re: [NAGDU] Notice of Proposed Rule-Making regarding service
> animals on airplanes
>
> Really? I thought we got done with this documentation and early
> check-in nonsense last year, or was it the year before. The fight never
ends.
> Tracy
>
>
> -----Original Message-----
> From: NAGDU [mailto:nagdu-bounces at nfbnet.org] On Behalf Of
> judotina48kg--- via NAGDU
> Sent: Wednesday, January 22, 2020 11:39 PM
> To: 'NAGDU Mailing List, the National Association of Guide Dog Users'
> Cc: judotina48kg at gmail.com
> Subject: [NAGDU] Notice of Proposed Rule-Making regarding service
> animals on airplanes
>
> Hello Everyone- I have pasted the DOT proposed regulations below my
> signature.
>
> Tina Thomas -President-CAGDU-NFBCA
>
>
>
>
>
> https://www.transportation.gov/individuals/aviation-consumer-protectio
> n/noti ce-proposed-rulemaking-traveling-air-service-animals
>
>
>
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>
>
>
> U.S. Department of Transportation Seeks Comment on Proposed Amendments
> to Regulation of Service Animals on Flights
>
>
>
>
> WASHINGTON - The U.S. Department of Transportation today announced
> that it is seeking public comment on proposed amendments to its Air
> Carrier Access Act (ACAA) regulation on the transportation of service
animals by air.
>
> The Notice of Proposed Rulemaking (NPRM) on Traveling by Air with
> Service Animals can be found HERE and provides the public with 60 days
> to comment on the proposed changes.
>
> Today's NPRM is intended to ensure a safe and accessible air
> transportation system. It addresses concerns raised by individuals
> with disabilities, airlines, flight attendants, airports, other
> aviation transportation stakeholders, and other members of the public,
> regarding service animals on aircraft. The Department recognizes the
> integral role that service animals play in the lives of many
> individuals with disabilities and wants to ensure that individuals
> with disabilities can continue using their service animals while also
> reducing the likelihood that passengers wishing to travel with their
> pets on aircraft will be able to falsely claim their pets are service
animals.
>
> The NPRM proposes to:
>
>
> * Define a service animal as a dog that is individually trained to
do
> work or perform tasks for the benefit of a person with a disability;
>
> * No longer consider an emotional support animal to be a service
> animal;
>
> * Consider a psychiatric service animal to be a service animal and
> require the same training and treatment of psychiatric service animals
> as other service animals;
>
> * Allow airlines to require forms developed by DOT attesting to a
> service animal's good behavior, certifying the service animal's good
> health, and if taking a long flight attesting that the service animal
> has the ability to either not relieve itself, or can relieve itself in
> a sanitary manner;
>
> * Allow airlines to require passengers with a disability who are
> traveling with a service animal to check-in at the airport one hour
> prior to the travel time required for the general public to ensure
> sufficient time to process the service animal documentation and
> observe the animal;
>
> * Require airlines to promptly check-in passengers with service
> animals who are subject to an advanced check-in process;
>
> * Allow airlines to limit the number of service animals traveling
> with
> a single passenger with a disability to two service animals * Allow
> airlines to require a service animal to fit within its handler's foot
> space on the aircraft;
>
> * Continue to allow airlines to require that service animals be
> harnessed, leashed, tethered, or otherwise under the control of its
> handler;
>
> * Continue to allow airlines to refuse transportation to service
> animals that exhibit aggressive behavior and that pose a direct threat
> to the health or safety of others; and
>
> * Continue to prohibit airlines from refusing to transport a service
> animal solely on the basis of breed.
>
> Comments on the NPRM must be received within 60 days of the date the
> notice is published. The NPRM can be found at regulations.gov, docket
> number DOT-OST-2018-0068.
>
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