[NAGDU] Notice of Proposed Rule-Making regarding service animals on airplanes

Sarah Calhoun sc-tico at att.net
Thu Jan 23 15:31:08 UTC 2020


The NPR states that they can limit 2 service dogs for one passenger, not 2 service dogs per flight.

Here is the NPR statement:

Department proposes to define a service animal, under its ACAA regulations in 14 CFR Part 
382, as a dog that is individually trained to do work or perform tasks for the benefit of a qualified 
individual with a disability, including a physical, sensory, psychiatric, intellectual, or other 
mental disability.0F1 Furthermore, this NPRM proposes to allow airlines to recognize emotional 
support animals as pets rather than service animals. The NPRM also proposes to allow airlines 
to require all passengers with a disability traveling with a service animal to complete and submit 
to the airline forms developed by DOT attesting to the animal’s training and good behavior, 

1 The Department’s proposed definition of a service animal in this rulemaking is similar to the definition of a service 
animal in the Department of Justice (DOJ) regulations implementing the Americans with Disabilities Act (ADA), 28 
CFR 35.104 and 28 CFR 36.104. However, the Department proposes a number of service animal provisions in this 
proposed rulemaking that differ from DOJ’s ADA service animal requirements. 

 
certifying the animal’s good health, and attesting that the animal has the ability either not to 
relieve itself on a long flight or to relieve itself in a sanitary manner. In addition, this NPRM 
would clarify existing prohibitions on airlines’ imposing breed restrictions on service animals 
and would allow airlines to set policies to limit the number of service animals that one passenger 
can bring onboard an aircraft. This NPRM would also generally require service to be harnessed, 
leashed, or otherwise tethered. This NPRM also proposes requirements that would address the 
safe transport of large service animals in the aircraft cabin and would clarify when the user of a 
service animal may be charged for damage caused by the service animal. Finally, this NPRM 
addresses the responsibilities of code-share partners, among other provisions.


Best,
Sarah
-----Original Message-----
From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Cindy Ray via NAGDU
Sent: Thursday, January 23, 2020 8:44 AM
To: 'NAGDU Mailing List, the National Association of Guide Dog Users' <nagdu at nfbnet.org>
Cc: cindyray at gmail.com
Subject: Re: [NAGDU] Notice of Proposed Rule-Making regarding service animals on airplanes

I downloaded a .pdf file, too, but it doesn't seem to be the whole thing.
OK, so here's the deal.
1) Completion of the form.
2)Health records
3) Certification that your dog has been trained and that from a training program.
4) Arriving early so that your dog can be observed.
5) The airline can limit the number of service animals, which if it is dogs, should be called "Service Dogs", and not "Service animals", to two on a flight,.
6) Guide horses should be included.
I realize that there have been some issues, but people using service dogs legitimately should not be punished for what people who can't be without their pets do.
I am not certain you can send it to the list. You could try or you could send it to me.
Cindy Lou Ray
cindyray at gmail.com


-----Original Message-----
From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Elizabeth Campbell via NAGDU
Sent: Wednesday, January 22, 2020 10:10 PM
To: NAGDU Mailing List, the National Association of Guide Dog Users <nagdu at nfbnet.org>
Cc: Elizabeth Campbell <batescampbell at gmail.com>
Subject: Re: [NAGDU] Notice of Proposed Rule-Making regarding service animals on airplanes

Hello cindy, I was able to download the PDF of the nprm. Can I send it as an attachment to this list? Also, it looks like over 600 comments were submitted thus far. There are links on the site to tweet or post on social media. I've only read a few paragraphs, but the two things that stand out so far to me are that the DOT wants to classify emotional support animals as pets and that anyone with a disability must complete a form attesting to the good health of their dogs. I thought we were successful in stopping this practice with the airlines.

On Wed, Jan 22, 2020 at 10:05 PM Cindy Ray via NAGDU <nagdu at nfbnet.org>
wrote:

> Oh, good grief. Anyway, I have seen enough to know that I am impressed 
> how they want us safe and the airlines not inconvenienced.
> Cindy Lou Ray
> cindyray at gmail.com
>
>
> -----Original Message-----
> From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Jordan Gallacher 
> via NAGDU
> Sent: Wednesday, January 22, 2020 9:45 PM
> To: Cindy Ray via NAGDU <nagdu at nfbnet.org>
> Cc: Jordan Gallacher <jordangandoliver at gmail.com>
> Subject: Re: [NAGDU] Notice of Proposed Rule-Making regarding service 
> animals on airplanes
>
> My best guess is there are a ton of people trying to comment and it 
> cannot handle all the traffic. It took me around two hours to finally 
> get it to show up properly. And even when I searched for the docket 
> number it would not even find it until a couple hours ago.
> Jordan
>
> Sent from my iPhone
>
> > On Jan 22, 2020, at 10:29 PM, Cindy Ray via NAGDU <nagdu at nfbnet.org>
> wrote:
> >
>
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--
Elizabeth Campbell
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