[Wasagdu] Sunset the CA Guide Dog Board

[Becky Frankeberger]

April 21, 2017
Dear Assembly Member -
Guide Dogs for the Blind, the largest guide school in North America and
correspondingly the largest guide school in California, urges you to vote
"NO" on
AB 1705, which would extend the term of the California State Board of Guide
Dogs
for
the Blind for another four years. The California State Board of Guide Dogs
for the
Blind
is a regulatory body created by the Legislature in 1947. It was established
at a
 time
 when guidance and regulation of guide dog school programs in the State of
 California
 was deemed necessary. The stated purpose of the Board is the public
 protection of
 guide dog users in California.
 Our clients and other guide dog consumers in the State of California, many
 of whom
 have contacted you directly, are clear that they do not want or feel they
 need the
 State
 Board.
 In addition, the State Board places an undue burden on the guide dog
schools
 in
 California. With the passing of SB 1331, schools from outside of California
 can operate
 within the State unregulated. The justification for this is that the
schools
 are
 certified
 through the International Guide Dog Federation (IGDF), globally considered
 the highest
 standard any guide dog program can attain. All three guide dog schools in
 California
 are certified through IGDF, thereby meeting the requirements for safe and
 appropriate
 instruction and protection put forth to all consumers through SB1331.
 Guide dog schools within California are required to pay substantial fees to
 the Board
 as
 a requirement of operation within the State. However, SB 1331 has exempted
 schools
 outside the State that are IGDF certified from paying fees or having to
 qualify in
 order to
 operate within the State. We believe that this is an undue burden on
 California schools
 and penalizes us relative to our out-of-state counterparts.
 Guide Dogs for the Blind pays approximately 80% of all of the fees paid to
 the Board.
 Last year we were required to pay $124,000, not including individual
 licensing fees
 or
 renewals. This is a significant amount of money for a non-profit to pay,
 particularly
 because we also pay fees to be IGDF certified and are being held to a
higher
 standard
 through IGDF than that of the State Guide Dogs for the Blind Board.
 SB1331 clearly states that the Board does not represent all guide dog users
 in
 California, but only those who have graduated from a California guide dog
 school.
 This
 distinction places responsibility on the consumer to pick a California
 school if
 they want
 the protection of the Board - this limits options for the consumer as well
 as further
 diluting the mission of the Board because the State Board protects only a
 subset
 of
 guide dog users within California.
 In conclusion, we believe that the California State Guide Dogs for the
Blind
 Board
 is
 redundant and should be sunsetted. The quality of the guide dog industry is
 determined
 and enforced through the IGDF, not through the California State Guide Dog
 Board.
 The
 IGDF has a much broader reach within California because they oversee and
 protect
 every guide dog handler within the State who has chosen to receive services
 from
 an
 IGDF accredited school. The State Board only protects those consumers from
 California-based schools. No other state has a board, and we are unaware of
 any
 evidence that non-California, IGDF-certified guide dogs schools perform
 significantly
 worse with respect to their instruction than IGDF-certified California
 schools.
 We, therefore, urge you to vote "NO" on AB 1705.
 Sincerely,
 Christine Benninger
 President and CEO
 Guide Dogs for the Blind

 Becky Frankeberger
 Butterfly Knitting
 -  Ponchos
 -  Afghans
 -  Shawls
 -  Custom Knitting
 360-426-8389
 becky at butterflyKnitting.com

 www.butterflyknitting.com