[NAGDU] Important and time sensitive! Federal Register now accepting comments on DOT form required for air travel with service dogs. Due on1/12

Tue Jan 9 01:56:53 UTC 2024

Sarah, I just read your email. Is there a form or do you just send an 
attachment to that link in the form of a letter? Trying to read thru all 
the government googly gook is a overwhelming. It's like they don't 
really want you to respond.

On 1/8/2024 2:00 PM, Sarah Calhoun via NAGDU wrote:
>                                  Please take the opportunity to voice your
> opinion on the Department of Transportation service dog air travel forms on
> the Federal Register.  The deadline for comments is Friday, January 12,
> 2024. Please see below for more information and feel free to share.
>
>   
>
> Kind regards,
>
> Sarah Calhoun, GDUI President
>
> Dear Members  of the Service dog community,
>
>   
>
> It has com     e to our attention that the U.S. Department of Transportation
> form required for air travel with service dogs is now under review. The
> Federal Register is now accepting comments on this form until January12th,
> 2024, or this coming Friday.
>
>   
>
> If you would like to provide your input, please  submit to the Federal
> Register at this link:
>
>   
>
> https://www.federalregister.gov/documents/2023/11/13/2023-24885/notice-of-su
> bmission-of-proposed-information-collection-to-omb-agency-request-for-reinst
> atement-of
>
>   
>
> You may file comments identified by the docket number DOT-OST-2018-0068 by
> any of the following methods:
>
> . Federal Rulemaking Portal: Go to  <https://www.regulations.gov>
> https://www.regulations.gov and follow the online instructions for
> submitting comments. (You may access comments received for this notice at
> <https://www.regulations.gov> https://www.regulations.gov by searching
> docket DOT-OST-2018-0068.)
>
> . Mail: Docket Management Facility, U.S. Department of Transportation, 1200
> New Jersey Ave. SE, West Building Ground Floor Room, W12-140, Washington, DC
> 20590-0001;
>
> . Hand Delivery: West Building Ground Floor, Room W12-140, 1200 New Jersey
> Ave. SE, between 9 a.m. and 5 p.m., Monday through Friday, except Federal
> holidays. The telephone number is 202-366-9329.
>
> Instructions: You must include the agency name and docket number
> DOT-OST-2010-0054 at the beginning of your comment. All comments received
> will be posted without change to  <https://www.regulations.gov>
> https://www.regulations.gov, including any personal information provided.
>
>   
>
>   
>
> Below is a sample of comments that we intend to submit. Feel free to use
> this as a basis for your comments.
>
>   
>
> If you have any questions please contact:
>
> Moira Shea: moirashea at verizon.net <mailto:moirashea at verizon.net>
>
> Or
>
> Martha Steele: marthajs at verizon.net <mailto:marthajs at verizon.net>
>
>   
>
> With appreciation,
>
>   
>
> Moira Shea and Martha Steele
>
>   
>
> Comment:
>
>   
>
> I am a blind traveler who travels frequently domestically and
> internationally with my service dog. I have been travelling with a guide dog
> for the past 30 years without any incidence. But Since the US Department of
> Transportation (DOT) started to require me to fill out an inaccessible form
> (in violation of Section 504 of the Rehabilitation Act), flying has become
> very problematic for me.
>
>   
>
> The DOT Service Animal Air Transportation Form should be greatly simplified
> in fully accessible format to conform generally with the requirements of the
> Americans with Disabilities Act (ADA). Indeed the most recent version of the
> Air Carrier Access ACT (ACAA) aligned its definition of service dogs as
> defined within ADA. ADA only permits two questions of those individuals who
> have a service animal:
>
> 1.	Is your animal a service animal?
> 2.	If so, what service does it perform?
>
>   
>
> Currently, the DOT form is burdensome, lengthy, requires the service animal
> handler to insert the service animal name eleven times, and asks for far
> more (and irrelevant) information than is allowed under ADA. Below is a
> partial list of what the current form requires:
>
>   
>
> 1.	Handler's name, address, email, and phone number
> 2.	Service Dog's name, with accompanying details on dog, such as breed,
> weight, gender, and whether spayed or neutered
> 3.	Dates of dog's rabies vaccination and expiration
> 4.	Handler statement that the dog is free of fleas, ticks, or other
> diseases that might affect humans or other animals
> 5.	veterinarian name and phone number
> 6.	Handler certification that service animal performs certain services
>
> 7.    Name of trainer or organization and phone number
>
> 8.    Handler certification that animal has been trained to behave in public
>
> 9.	Handler certification that he/she understands that service animal
> must be under control at all times
> 10.	Handler certification that service animal is not aggressive
> 11.	Warning that if service animal does not behave, airline can charge
> pet fee
> 12.	Handler certification that service animal has not behaved poorly or
> caused injury to other dogs
> 13.	Handler certification that he/she understands that service animal
> must be harnessed at all times
>
>   
>
> If DOT continues to require completion of a form for service animal users to
> travel by air, the form should contain no more than four questions, as
> follows:
>
>   
>
> Are you traveling with a service animal?
>
> If so, what service does it perform?
>
> What is the name of the service animal?
>
> What is the name and phone number of the school where the service animal was
> trained?
>
>   
>
> However, I strongly urge that there be no form required for the service
> animal handler to complete. The purpose of the ACAA is to make flying more
> accessible to individuals with disabilities. Instead, in addition to
> requiring that the handler complete the long, repetitive, and burdensome DOT
> form inaccessible to many, the handler faces different requirements from
> every airline. For example, Delta Airlines requires that the handler
> complete the DOT form on the airlines' website, not accepting the already
> completed DOT form with service animal identification number. Other
> airlines, such as Jet Blue, require completion of an additional form beyond
> the DOT form before they will give approval for the service animal's travel,
> increasing the burden even more on the service animal handler. In addition,
> the current process sometimes creates unnecessary and delayed travel
> approval from the airlines.
>
>   
>
> To truly make airline travel more accessible and in conformance with ADA, I
> propose that all guide dog schools input into the DOT website the name of
> the handler, the name of the service animal, and the name and phone number
> of the school where the pair graduated from. The airline personnel can then
> enter the DOT website to verify that the passenger is traveling with a
> trained service animal in accordance with ACAA. This takes the burden off
> the service animal handler, addresses concerns that many handlers face
> inaccessibility issues with online forms for a variety of reasons, and
> restores the purpose of the ACAA intent to improve air travel access for
> those with disabilities.
>
>   
>
> The requirements for air travel are also far greater than for any other mode
> of travel or entering public spaces. No other mode of transportation, such
> as rail, bus, or ferry/ship, requires any such documentation. Entering
> public spaces such as hotels, restaurants, hospitals, grocery stores,
> theaters, or museums, also do not require burdensome documentation. Why is
> travel on an aircraft any different from other modes of transportation or
> places frequented by the general public?
>
>   
>
> Thank you for your careful attention to these comments.
> Sincerely,
>
>   
>
>   
>
>   
>
>   
>
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