International Association of
Assistance Dog Partners
COALITION OF ASSISTANCE DOG ORGANIZATIONS P.O. Box 638 Sterling Heights, MI 48310
John Wodatch, Director,
Disability Rights Section
U.S. Department of Justice
Civil Rights Division
P.O. Box 66738
Washington, D.C. 20035-6738
Dear Mr. Wodatch,
In April 2001, a delegation from the International Association of Assistance Dog Partners (IAADP), Guide Dog Users, Inc. (GDUI) and Assistance Dogs International (ADI) met with you and representatives from the Housing and Civil Enforcement section to propose an improved definition of a "service animal". We discussed with you the problems that the original regulatory language has inadvertently created for the assistance dog movement, the larger disabled community and the business world.
The organizations listed above have formed the Coalition of Assistance Dog Organizations (CADO). IAADP is the largest cross disability consumer advocacy organization for individuals partnered with guide, hearing and service dogs in the USA; GDUI is the largest consumer advocacy organization for blind and visually impaired individuals working with guide dogs; ADI is the largest coalition of non profit training programs which provide guide, hearing and service dogs to the disabled community.
We learned that due to security concerns involving the anthrax threat, our letters and publications may not have reached you by standard mail . Please accept this letter as an update of CADO's activities and concerns since our initial meeting.
During our April 2001 presentation and subsequent discussion, we highlighted two issues of concern to the members of our respective organizations: (1) task training as the determining factor in whether an animal is a "service animal"; and (2), common misunderstanding and abuse of the phrase"minimal protection". Upon learning that the regulatory review process concerning the definition might take several years, our delegation suggested your office might consider addressing these issues in an update of the 1996 "Service Animal FAQ".
On January 22, 2002, news swept the assistance dog community that DOJ's ADA Homepage carried an updated FAQ from the DOJ's Disability Rights section. This important document deserves accolades for its decisive stand on several issues.
CADO is writing to express our profound appreciation for the DOJ's responsiveness to the concerns of our members. CADO appreciates the addition of language supporting the fact that businesses may now ask the question, "What tasks does your service animal perform?" This ingenious addition unequivocally communicates the message to all people with disabilities, their families, trainers and advocacy groups that TASK TRAINING is the litmus test of legitimacy. Those who want to bring an animal into places of public accommodation can no longer ignore the quintessential difference between a pet and a service animal.
When CADO member organizations updated consumers and training providers about the new guidance from the Disability Rights section, their reaction was most gratifying. We think it is highly significant that we have not received one word of negative feedback from our constituents.
We appreciated Jeanine Worden's acceptance of our invitation to attend the January 2002 CADO meeting in an advisory capacity, and to address a large audience of consumer advocates and training organizations during the CADO workshop at IAADP's conference the following day. Her enlightening talk on the step by step protocol that the regulatory review process entails allows us to be better prepared for the future public comment period(s), ensuring the voices of our constituents will be heard.
To supplement DOJ's efforts at clarifying the intent of the Americans With Disabilities Act with respect to service animal access, CADO has developed a public service announcement for radio stations and an editorial piece for local newspapers. Distributing these tools gives our respective members the opportunity to participate in a campaign to educate the public and business community about the differences between a pet and a service animal.
Recently CADO has received communication from various sources that an individual presenting a private national certification scheme for service animals has been in contact with you and others at the Department of Justice regarding his negative opinion of enabling businesses to ask about task training as a means of identifying service animals. CADO does not endorse or support any plan for national certification of ervice animal teams as a means of identification for public access.
Pleased be assured the Department of Justice has solid support from CADO and the assistance dog movement for the Jan. 22, 2002 Business Brief update with the question,"What tasks does your service animal perform for you?" We also applaud the comments made during your 2001 interview with the Great Lakes ADA Learning Center, differentiating a service animal from a pet or emotional support animal. CADO members cherish the access rights granted to assistance dog teams under the ADA and want to preserve them for the next generation. It is safe to say that people with disabilities who are able to lead productive lives with the assistance of trained animals find the attitude of some that "anything goes because of the ADA" most disturbing and harmful to access rights for all in the long-term. We thank you and your division along with the Department of Justice for upholding "task training" as a crucial distinction between a pet and a genuine service animal. Also for the recognition that there is no viable, credible method of national certification for assistance dog teams in the foreseeable future.
CADO plans to hold its third annual meeting in January, 2003 in San Antonio, Texas. We hope to report further progress on national education efforts regarding task-specific eligibility for public access. We invite you and interested members of your staff to contact us for more information about this meeting and other work of the coalition, including our public service announcement and editorial piece. Again, we appreciate the stand the Disability Rights section of the Department of Justice has taken regarding service animal issues and we continue to support your work.
Joan Froling, IAADP Chairperson
Debbie Grubb, GDUI President
Linda Jennings, ADI President
Letter dated and distributed August 5, 2002
Contact InformationInternational Association of Assistance Dog Partners
38691 Filly Drive
Sterling Hts., MI 48310
(586) 826-3938 IAADP@aol.com
Guide Dog Users Inc.
14311 Astrodome Drive
Silver Spring, Maryland 20906
(888) 858-1008 email@example.com
Assistance Dogs International
Post Box 5174
Santa Rosa, CA 95402
(707)586-0798 (Linda Jennings)
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