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

Mon Jan 8 23:04:41 UTC 2024

In the event you didn't see this from nagdu.

Shane Popplestone
President of the Ohio Association of blind students
Co-chair of the ohio newsline committee
member of the Grater Akron Chapter
member of Ohio Association of Guide Dog users
spopplestone.nfb at gmail.com
234-716-2208
You can live the life you want!

------ Forwarded Message ------
>From "Sarah Calhoun via NAGDU" <nagdu at nfbnet.org>
To "NAGDU Mailing List, the National Association of Guide Dog Users" 
<nagdu at nfbnet.org>
Cc "Sarah Calhoun" <sc-tico at att.net>
Date 1/8/2024 6:00:45 PM
Subject [NAGDU] Important and time sensitive! Federal Register now 
accepting comments on DOT form required for air travel with service 
dogs. Due on1/12

                                 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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