[NYAGDU] FW: [NAGDU] GDF's comments on Air Travel NPRM

[Tracy Carcione]

These are the Guide Dog Foundation's comments on the Department of Transportation's proposed rules converning air travel and service dogs.
Tracy


-----Original Message-----
From: NAGDU [mailto:nagdu-bounces at nfbnet.org] On Behalf Of Jenine Stanley via NAGDU
Sent: Tuesday, March 31, 2020 2:13 PM
To: NAGDU Mailing List, the National Association of Guide Dog Users
Cc: Jenine Stanley
Subject: [NAGDU] GDF's comments on Air Travel NPRM

This was sent today to GDF grads. This is not the complete message but the greeting and initial paragraph wasn’t significant. 


We encourage you to send your comments as well.  If you agree with the comments from the Guide Dog Foundation, use them in your submission. Be heard!  Comments MUST be filed before April 6, 2020 11:59 PM ET. Click here to leave your comment today <http://guidedog.informz.net/z/cjUucD9taT05MjM1MjU1JnA9MSZ1PTEwMjY1MDUwODcmbGk9NzUzMjI0MTY/index.html>! 

This is our opportunity as a community to ensure flying with assistance dogs is more accessible and safer for all our graduate teams.

The Guide Dog Foundation strongly supports the Department’s proposed Definition of a Service Animal align with the definition of that of the Americans with Disabilities Act (ADA) so only dogs, that have been individually trained to perform tasks for the benefits of a qualified individual with a disability; including a physical, sensory, intellectual or psychiatric disability, will be considered a service animal. This will decrease confusion and enhance the safety of passengers and crew. We also strongly support the proposal that psychiatric service dogs, because they are trained for public access and tasks to mitigate their partners disabilities, be treated as all other service dogs, not as emotional support animals.
The Guide Dog Foundation supports the proposed definition that Emotional Support Animals be recognized as pets by the airlines and be subject to the airline regulations required for flying with pets. Emotional support animals have not been trained to perform tasks that mitigate their partners disability nor for public access. They are not prepared for the situations that they may face when traveling by air or to handle the various stimuli experienced. Because of this, they are more likely to misbehave, cause a disturbance or have accidents than highly trained and desensitized service dogs.
The Guide Dog Foundation supports the Definition of a Service Animal Handler as the person who is benefiting from the help of the service dog. The Guide Dog Foundation also supports a third party “caregiver” in cases where a service dog is helping a disabled person or child who needs extra support with his or her service dog.
The Guide Dog Foundation does not support the DOT’s proposed ruling regarding Large Service Animals. Most service dogs are able to curl up under their partner’s feet on an airplane. There are some individuals with disabilities however that need a larger service dog to perform tasks to assist them when walking or to help them up when they fall. They cannot utilize a smaller dog to mitigate their disabilities as the small size would prohibit this. Those traveling with larger service dogs should be afforded the same comforts as the general public.
 
We ask that the DOT continue to advise airlines to seat passengers traveling with a service animal in a location on the aircraft where the larger service dog can be accommodated, such as next to an empty seat. If that is not possible, other passengers can be asked if they mind sharing foot space with a larger service dog upon checking in.

The passenger should not be booked on a later flight just because they have a large service dog and we firmly believe that no animal should ever be separated from its partner and placed within the cargo hold.
The Guide Dog Foundation disagrees with the DOT that one person should be able to fly with two service dogs. There should only be one service animal traveling with a person. This is not a practice that is endorsed by any accredited service dog programs in North America or utilized by legitimate service dog teams. If a person has multiple disabilities, one service dog can be trained to do multiple things to mitigate that person’s disabilities.
The Guide Dog Foundation agrees with DOT that the airlines should be able to ascertain if an animal is not under the control of its handler, and poses a direct threat to the travel or safety of other passengers. Also, all service dogs should be under control and encourage the definition of under control as being harnessed, leashed, or tethered. As a dually accredited organization by IGDF and ADI, the Guide Dog Foundation welcomes the opportunity to instruct the airline employees in appropriate service dog behavior.
The Guide Dog Foundation does not support the DOT proposed rule to allow airlines to require forms, as they will undoubtedly be an additional hardship for individuals who travel with a service animal.

Instead we recommend that checkboxes, to be completed when making a reservation, be utilized. When individuals with service animals check the boxes, they are certifying that their service dog is a tasked trained animal required for a disability, that their service animal is trained for public access and that they understand that falsely representing this animal as a service dog is a crime. Through the use of checkboxes, the handler can also attest to the health of their service dog and provide a relief attestation for flights over eight hours. 

In order to assure that individuals with disabilities are afforded the same experience when traveling, it is imperative that airlines insure full accessibility of their websites, apps and communication. Regardless of the attestations, the Guide Dog Foundation supports the removal of any dogs that are not under control and misbehaving.
The Guide Dog Foundation believes that health forms are grossly unnecessary and would not provide any additional information that the check box attestation and rabies information (tag number, veterinarian’s name and number and expiration date), provides at time of booking.
The Guide Dog Foundation strongly disagrees with the DOT proposed rule to require those with service animals to check in 1 hour before the general public. This practice would cause an unjust burden on individuals with disabilities utilizing service dogs that the general public does not have to endure. In addition, individuals with disabilities would be segregated from the general public and their traveling party. A person with a disability is entitled to the same rights and opportunities as the general public, including checking in online 24 hours in advance, skipping the check in line if not checking a bag ,and remaining with his or her travel party throughout the entire airport stay.
Send in your comments before April 6, 2020 11:59 PM ET. Click here to leave your comment. <http://guidedog.informz.net/z/cjUucD9taT05MjM1MjU1JnA9MSZ1PTEwMjY1MDUwODcmbGk9NzUzMjI0MTY/index.html>
 

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