[NAGDU] Notice of Proposed Rule-Making regarding service animals on airplanes
sunshine
halogirl817 at gmail.com
Fri Jan 24 14:16:24 UTC 2020
In reading the material, it is my point of you that each individual could have two dogs. I did not have the impression that only two people on the plane could have dogs. I have been on the plane with three other people going to the Seeing Eye in the past. Secondly I believe that we are asked to be there one hour earlier than the other travelers. Which means that if we are to be there an hour and a half Early, then we, who have guide dogs must be there 2 1/2 hours early. That doesn’t seem reasonable to me. There are several things that I don’t like about this particular documentation. I believe that we would be spending a lot more money filling out forms with our vets as I know when I did a couple of years ago the cost was pretty high.
Sunshine
Sent from my iPhone XR
> On Jan 23, 2020, at 8:39 PM, melissa R. Green via NAGDU <nagdu at nfbnet.org> wrote:
>
> Hmm, the service animal number on flights is a concern. It isn't very
> clear. Do they mean, per each individual or as a whole group. If it is
> about each individuals then I am okay with it. But not if there has to be
> only two on a plane. That can cost lots of problems with conventions, or
> me and two other people having a service animal. I am concerned about the
> checking in early, and all of the forms. I was able to upload a notice and
> a record from my vet with Delta.
> I will be paying attention to these new rules and their development.
>
>
> -----Original Message-----
> From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Cindy Ray via NAGDU
> Sent: Thursday, January 23, 2020 8:38 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
>
> Hi, Danielle,
> I like what you have said here. These are all valid points. However, I do
> take exception to one of them and wonder why you like this:
> * restricting the number of service animals to two Why do you think this
> is valid? Most often it wouldn't be an issue one way or another, but let's
> say an NFB or ACB Convention ends and a lot of people are getting on the
> same plane. This was truly something to consider in Orlando when a huge
> number of folks were flying to Atlanta to make connections. There could
> easily be many more dogs on the flights than two.
> So would you want us to have to state that we have a dog, which of course
> is probably not an issue anyway if these rules were passed? How would they
> decide who would get to go on the flight? Would it be a lottery? I realize
> this doesn't happen a lot, but I know there are certainly instances when
> it could. The Washington Seminar comes to mind.
> Thanks for your help on this. I really do like what you have written.
> Cindy Lou Ray
> cindyray at gmail.com
>
> -----Original Message-----
> From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Danielle Sykora via
> NAGDU
> Sent: Thursday, January 23, 2020 9:15 AM
> To: NAGDU Mailing List, the National Association of Guide Dog Users
> <nagdu at nfbnet.org>
> Cc: Danielle Sykora <dsykora29 at gmail.com>
> Subject: Re: [NAGDU] Notice of Proposed Rule-Making regarding service
> animals on airplanes
>
> Here is what I wrote on another discussion about this. I intend to polish
> this and post an official comment soon.
>
> Things I like
> * No longer allowing ESAs (though I wouldn't be entirely opposed to
> exploring regulating them separately and more strictly)
> * Restricting service animals to dogs (though allowing miniature horses as
> an exception on a case-by-case basis like in the ADA could be explored)
> * classifying psychiatric service dogs as service dogs (which they are),
> not lumping them together with ESAs
> * restricting the number of service animals to two
>
> things I don't like
> * Having to check in an hour early. If this is in addition to the normal
> time, this would mean checking in three hours early for domestic flights
> and four hours early for international. That's forcing the service animal
> to go an extra hour without relieving, and they are already having to go a
> long time in some cases.
> * Providing attestations of behavior. If someone wants to pretend their
> pet is an SD, what is stopping them from simply lying on the form? There
> aren't any consequences for doing so. Having the form filled out by a
> third party will never be reliable, because who is a reliable third party?
> Vets may know nothing about training and behavior, and there isn't any
> requirement for dog trainers to be licenced. Owner trainers can't just
> show a program issued ID card, and some service dog programs (yes even ADI
> certified ones) produce some truly terrible dogs.
> * Providing health records from a veterinarian. Getting an annual report
> filled out would not tell you all that much about the dog. A dog could be
> free of parasites today, but not next week. Anything that must be filled
> out more often than annually would force handlers to pay an unnecessary
> fee for an office visit at minimum. I'm also concerned that airlines will
> start forcing people to give their dogs elective vaccinations. For
> example, bordetella is optional and some owners and vets will titer for
> distemper, but what if an airline decides these are now required?
> * Size restrictions. If the dog is sprawled across the isle or taking up
> the entire row, of course this is a problem. The most common breeds of
> service dogs are Labs and Goldens though, so restricting large dogs would
> have a huge impact on service dog handlers Essentially, that would
> restrict most guide and mobility dogs. Learning how to tuck under seats is
> part of public access training. I've seen 90 lb dogs that curl up tightly,
> and 30 lb dogs that are allowed to stretch out in the isle.
> * The assertion that employees should have no responsibilities at all.
> If animals are not removed from airports for poor behavior, literally
> nothing will solve the problem--no amount of paperwork will ever be the
> same as proper training. I've seen countless horrifically behaved dogs in
> public with multiple employees witnessing their behavior, but nothing is
> ever done.
> If an employee ignores a dog lunging an growling at a person in the
> airport and that dog proceeds to bite a flight attendant an hour later,
> that employee is partially responsible.
>
> I don't think it is unreasonable to ask for proof of rabies, because this
> is a requirement for all dogs. It is also the only significant disease
> that would be directly transferred from dog to human that is vaccinated
> against.
> I wish this could be provided in a way that didn't require advanced notice
> or additional burdens. Perhaps anyone traveling with a dog would be
> required to show a rabies certificate before going through the security
> checkpoint or something.
>
> Danielle
>
>> On 1/23/20, Cindy Ray via NAGDU <nagdu at nfbnet.org> wrote:
>> It was the year before as I recall. And another thing. (Tracy, this
>> isn't about you.) I don't think any of us should ever write to this
>> list and say "What is NAGDU going to do about this? Whether we are
>> members of NAGDU or not, it is up to all of us to "do something about
>> it." DGUI, NAGDU, and everybody who uses a dog or doesn't needs to do
>> something about it. I don't want to see people posting to this list
>> "What is NAGDU going to do about it." If we are in NAGDU we will want
>> to support what NAGDU does; if we are not, we want to support what
>> NAGDU does because it will make a difference to all of us in the end.
>> Cindy Lou Ray
>> cindyray at gmail.com
>>
>>
>> -----Original Message-----
>> From: NAGDU <nagdu-bounces at nfbnet.org> On Behalf Of Tracy Carcione via
>> NAGDU
>> Sent: Thursday, January 23, 2020 7:59 AM
>> To: 'NAGDU Mailing List, the National Association of Guide Dog Users'
>> <nagdu at nfbnet.org>
>> Cc: Tracy Carcione <carcione at access.net>
>> Subject: Re: [NAGDU] Notice of Proposed Rule-Making regarding service
>> animals on airplanes
>>
>> Really? I thought we got done with this documentation and early
>> check-in nonsense last year, or was it the year before. The fight
>> never
> ends.
>> Tracy
>>
>>
>> -----Original Message-----
>> From: NAGDU [mailto:nagdu-bounces at nfbnet.org] On Behalf Of
>> judotina48kg--- via NAGDU
>> Sent: Wednesday, January 22, 2020 11:39 PM
>> To: 'NAGDU Mailing List, the National Association of Guide Dog Users'
>> Cc: judotina48kg at gmail.com
>> Subject: [NAGDU] Notice of Proposed Rule-Making regarding service
>> animals on airplanes
>>
>> Hello Everyone- I have pasted the DOT proposed regulations below my
>> signature.
>>
>> Tina Thomas -President-CAGDU-NFBCA
>>
>>
>>
>>
>>
>> https://www.transportation.gov/individuals/aviation-consumer-protectio
>> n/noti ce-proposed-rulemaking-traveling-air-service-animals
>>
>>
>>
>>
>>
>>
>>
>>
>> U.S. Department of Transportation Seeks Comment on Proposed Amendments
>> to Regulation of Service Animals on Flights
>>
>>
>>
>>
>> WASHINGTON - The U.S. Department of Transportation today announced
>> that it is seeking public comment on proposed amendments to its Air
>> Carrier Access Act (ACAA) regulation on the transportation of service
> animals by air.
>>
>> The Notice of Proposed Rulemaking (NPRM) on Traveling by Air with
>> Service Animals can be found HERE and provides the public with 60 days
>> to comment on the proposed changes.
>>
>> Today's NPRM is intended to ensure a safe and accessible air
>> transportation system. It addresses concerns raised by individuals
>> with disabilities, airlines, flight attendants, airports, other
>> aviation transportation stakeholders, and other members of the public,
>> regarding service animals on aircraft. The Department recognizes the
>> integral role that service animals play in the lives of many
>> individuals with disabilities and wants to ensure that individuals
>> with disabilities can continue using their service animals while also
>> reducing the likelihood that passengers wishing to travel with their
>> pets on aircraft will be able to falsely claim their pets are service
> animals.
>>
>> The NPRM proposes to:
>>
>>
>> * Define a service animal as a dog that is individually trained to
> do
>> work or perform tasks for the benefit of a person with a disability;
>>
>> * No longer consider an emotional support animal to be a service
>> animal;
>>
>> * Consider a psychiatric service animal to be a service animal and
>> require the same training and treatment of psychiatric service animals
>> as other service animals;
>>
>> * Allow airlines to require forms developed by DOT attesting to a
>> service animal's good behavior, certifying the service animal's good
>> health, and if taking a long flight attesting that the service animal
>> has the ability to either not relieve itself, or can relieve itself in
>> a sanitary manner;
>>
>> * Allow airlines to require passengers with a disability who are
>> traveling with a service animal to check-in at the airport one hour
>> prior to the travel time required for the general public to ensure
>> sufficient time to process the service animal documentation and
>> observe the animal;
>>
>> * Require airlines to promptly check-in passengers with service
>> animals who are subject to an advanced check-in process;
>>
>> * Allow airlines to limit the number of service animals traveling
>> with
>> a single passenger with a disability to two service animals *
> Allow
>> airlines to require a service animal to fit within its handler's foot
>> space on the aircraft;
>>
>> * Continue to allow airlines to require that service animals be
>> harnessed, leashed, tethered, or otherwise under the control of its
>> handler;
>>
>> * Continue to allow airlines to refuse transportation to service
>> animals that exhibit aggressive behavior and that pose a direct threat
>> to the health or safety of others; and
>>
>> * Continue to prohibit airlines from refusing to transport a
> service
>> animal solely on the basis of breed.
>>
>> Comments on the NPRM must be received within 60 days of the date the
>> notice is published. The NPRM can be found at regulations.gov, docket
>> number DOT-OST-2018-0068.
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
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>>
>>
>>
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