EMERGENCY CALL TO ACTION
( UPDATE: AS OF NOV. 4, 2005 YES, WE STILL NEED YOUR LETTERS . . . . Please keep them coming until further notice. Thank you! )
Please Call or Write Your Elected Officials In Congress
The United States Department of Transportation has issued proposed rules authorizing the airlines to charge a disabled passenger for an extra ticket if an assistance dog does not fit into the small amount of floor space directly in front of the disabled person's seat. Alternatively, the airline can separate the team and put the dog in cargo or make the team wait for a later flight.
These three options are unacceptable to the disabled community. This rule discriminates against, penalizes and disempowers the disabled traveler.
Friends and members of the International Association of Assistance Dog Partners (IAADP) have flooded the DOT Public Comment site with more than 1150 responses critical of these proposed rules. There is strong support for IAADP's common sense alternative proposal. To view these comments, visit: http://dms.dot.gov/search/document.cfm?documentid=303024&docketid=19482.
This issue is crucial to our freedom to travel with a guide, hearing or service dog.
If you are as outraged as members of IAADP, we strongly urge you to get in touch with your congressional representative and senators. Let them know about this important issue and ask them to contact the DOT on your behalf.
A personal letter from a constituent can have a beneficial result when the issue concerns the discriminatory treatment of disabled people and their canine assistants.
Let them hear from you before the Final Rule is published. There is a small window of time in which a letter from you could really make a difference!
You can be sure the DOT will respond to inquiries from your congressional or senatorial representative's office. Please give your elected officials the chance to help the assistance dog community before it is too late.
Below is a Model Letter for your consideration and Instructions on How to Submit a Letter. We also have a brief sampling of the responses the DOT received during the public comment period, which you may wish to include.
Your Address ( to show you live in
your Representative's District or State)
Date: month / day / year
I urgently request your help with an air travel issue of importance to me and other disabled Americans who work with guide, hearing and service dogs. A rule recently recommended by the Department of Transportation (DOT) for airline personnel would infringe on our ability and right to travel by air.
On November 4, 2004 DOT published a Notice of Proposed Rule Making in the Federal Register concerning air travel by passengers with disabilities. The stated goal was to clarify existing rules and make air travel more accessible for disabled Americans. However, a segment of that document would have the opposite effect for a portion of the disabled American community.
The area of concern focuses on the situation where a guide, hearing or service dog cannot fit within the floor space provided in front of the disabled passenger. In its Notice of Proposed Rule Making, DOT states:
"If no single seat will accommodate you may offer the option of purchasing a second seat, traveling on a later flight or having the service animal travel in the cargo hold."
On December 12, 2004 the International Association of Assistance Dog Partners responded to that document with a letter of Public Comment, raising strong objections to the segment dealing with air travel by passengers accompanied by service animals. The proposed rule discriminates against individuals whose disabling condition requires them to work with assistance dogs large enough to perform tasks such as guiding, wheelchair pulling, balance support or backpacking medical supplies. The DOT recommendations directed to airline personnel would make it virtually impossible for those working with large assistance dogs to continue traveling by air.
All three of the DOT recommended options are unacceptable and unconscionable! The first option, charging for a second seat, would disenfranchise many disabled persons, since few could afford to pay two fares to travel by air. Requiring the disabled passenger to take a later flight makes little sense since the same crowded conditions might exist on other flights. Furthermore, the uncertainty this would create, the fear of being forced to miss connections, scheduled pickups or appointments makes this option unworkable. The third recommendation, shipping the dog in the cargo hold is unacceptable because separating the service animal from the disabled partner threatens his /her independence.
The outrage and distress these DOT recommendations evoked in members of the disabled community and general public who responded to the NPRM can be viewed on the DOT's website. Of the more than 1,250 comments posted, over 1,150 focus on this issue, and request the elimination of those three options. ( See http://dms.dot.gov/search/document.cmf?documentid=303024&docketid=19482 )
Current airline practices of providing an empty seat where space is available or asking for a volunteer to share leg space with the assistance dog, have created excellent working relationships between disabled passengers and the airline industry.
I support the efforts of IAADP, a consumer organization representing more than 2000 disabled people working with specially trained dogs that perform disability mitigating tasks, to bring this matter to your attention. I would like to see the airlines continue their current practices of providing assistance dog teams with an accommodation in the cabin.
I suggest the following language, drafted by IAADP, be substituted for the DOT recommended amendment to the Air Carrier Access Act on this issue:
"If no single seat accommodates, you may offer the passenger sitting in a seat adjacent to the disabled passenger traveling with a large service animal a seat in the same class of service in another part of the cabin. If no seats are available in that class of service, you may ask for a volunteer willing to occupy the seat next to the disabled passenger requiring the sharing of leg room. If no volunteer is forthcoming and seats are available in another class of service in another part of the cabin, you may ask the adjacent passenger or the disabled passenger to occupy a seat in that other class of service."
These options would impose no financial cost on the airlines, would continue current airline practices and would truly implement the spirit of the Air Carrier Access Act..
On behalf of the more than 20,000 Americans working with assistance dogs I implore you to contact the DOT to support our ability to continue traveling by air without undue financial hardship.
How To Submit a Letter:
Alternatively, you may use some or all of this Model letter, providing you take care to personalize it.
Please do NOT copy our Model letter "as is" into an email. Don't print it out and submit it "as is" by snail mail. At the very least, you MUST personalize this letter by erasing our "directions" in italics and typing in your own name and address, your Representative's name and address, plus the Date.......at the end, you must sign it. Otherwise you show you don't care enough about this issue to submit a personal letter. Sending in a mere form "as is" is not going to help our cause.....we are concerned it will have a negative impact. Thank you for respecting this request.
Optional: add a postscript "PS" about your disability, the ways your dog assists you in the airport and plane cabin. Discuss how apprehensive you are about the proposed amendment and how much you'd appreciate your representative's help to ensure you can continue to fly with your assistance dog.
Optional: Print out and enclose the Sampling of Public Comment Letters, we have in this web section, giving your representatives and their staff, the benefit of the views of two very important organizations in the assistance dog field and the excellent points made by one of the many citizens who wrote to the DOT on this issue.
If you are NOT a disabled person, but instead you are a citizen who wants to support us on this urgent matter, please change the wording of the Model letter so it will make sense, changing things like "our dogs" to "their dogs".
It would be wonderful for your representatives to learn that members of the public care about this issue too! Please take time to re-write the model letter from a NON disabled person's perspective......or start fresh, composing your own letter from scratch. This is the way for you to be taken seriously when communicating with your elected officials.
If you need the address and/or phone number of your Congressman and the two Senators in your state, simply call a reference librarian at your local public library for this information.
If you wish to submit an e-mail letter to your representatives, you can visit the marvelous website whose link I found in IAADP's Assistance Dog Law section. Type in your address and zip code and it will immediately provide you with the names of your representatives, as well as links to enable you to submit a personal letter by e- mail to them and receive a reply. ( Visit: http://www.visi.com/juan/congress )
Please keep us informed by e-mailing Ed Eames or by phoning 586-826-3938 if your contact with elected officials yields any news we may not be aware of. We certainly would appreciate being informed.
Sampling of Letters sent to the Department of Transportation about their proposed regulatory amendment to the Air Carrier Access Act during the NPRM Public Comment Period ending March 4, 2005
* NOTE: Of the 1250 public comments received the DOT's Notice of Proposed Rule Making by the March 4th deadline, over 1150 of those letters addressed this specific access issue, protesting the appalling hardships this new rule would impose and asking the DOT to please reconsider!
Letter from a Citizen
In order to comply with the Congressional mandate this regulatory law must insure that people with disabilities with service animals do have equal access to commercial air travel. This regulatory change does not provide this access. Most service dogs could never fit under the space below the seat in front of the disabled passenger. What should be required is that airlines either provide accessible coach bulkhead seating with additional leg and foot space that can accommodate service animals or, if the airline chooses to not provide accessible coach bulkhead seating, the airline must provide an empty seat next to the passenger with the service animal, or must seat the passenger with the service animal in a business class or first class seat that provides the necessary floor space. It is wrong to allow airlines to eliminate seating areas that were designated for priority use by people with disabilities with service animals (and people with disabilities with fused or immobilized legs) and to then make the airlines decisions the burden of people with disabilities.
Assistance Dogs International's Letter
March 3, 2005
Department of Transportation
400 7th Street, SW., Room PL-401
Washington, DC 20590.
Docket Number OST-2004-19482
Dear Docket Clerk,
On behalf of the members of Assistance Dogs International, a coalition of approximately 100 programs training and placing Guide, Hearing and Service dogs with people with disabilities around the world, I would like to voice our support of considering assistance dogs as required medical equipment when traveling by air. Most assistance dogs are large retrievers necessary for pulling wheelchairs and helping people with balance or guiding issues. Dogs of this size frequently have problems fitting under a single seat in an airplane. Requiring persons with disabilities to buy an extra seat for the dog would seriously impact that person's ability to travel and imply discrimination against people with disabilities. We urge you to consider this issue carefully and not impose additional handicaps on people with disabilities. We support the language of the International Association of Assistance Dog Partners, "You may offer the passenger sitting in the seat adjacent to the disabled passenger traveling with a large service animal a seat in the same class of service in another part of the cabin. If no seats are available in that class of service, you may ask for a volunteer willing to occupy the seat next to the disabled passenger requiring sharing of leg room. If no volunteer is forthcoming and seats are available in another class of service, you may ask the adjacent passenger or the disabled passenger to occupy a seat in that other class of service."
Linda Jennings., President
The International Guide Dog Federation & the Seeing Eye's Letter
February 29, 2004
Department of Transportation
400 7th Street, SW., Room PL-401
Washington, DC 20590.
Docket Number OST-2004-19626-1
Dear Docket Clerk:
As the President of The Seeing Eye, Inc., the world's oldest dog guide school, I welcome the opportunity to comment on the Notice of Proposed Rule Making published in the Federal Register on November 4, 2004. My role as the Chairman of the International Guide Dog Federation, which represents 70 accredited dog guide programs in 26 countries worldwide, may add greater perspective to my viewpoint.
For over 15 years, graduates of The Seeing Eye traveling with their dog guides have relied on The Air Carrier Access Act to prohibit discrimination in airline service on the basis of disability. We appreciate the challenges inherent in accommodating all types of air travelers, and commend the airlines for their current practices that have improved access for people who are blind. Our graduates' experiences with U.S. air carriers have been overwhelmingly positive.
The prospect of further regulating a process that seems to be working quite well is most distressing to our graduates. We have received dozens of emails and telephone calls from graduates who are concerned about the Department's request for guidance regarding long-duration flights and the restrictive conditions that may be imposed on the rights of blind passengers when accompanied by their dog guides in the passenger cabin.
Long Duration Flights:
The Seeing Eye does not consider the issue of long-duration flights to be an area of concern, certainly not one that would require regulation by the Department of Transportation. Many of our graduates have successfully traveled with their dog guides on non-stop air travel from the United States to Australia, New Zealand and South Africa without incident. It should not surprise anyone that a dog can be content to be at rest for such a long period of time. It happens every night, with every dog. Our graduates commonly take their dogs out to relieve themselves after evening dinner, and then not again until breakfast time the following morning. In advance of a long air trip, our graduates restrict their dogs' intake of food and fluids. While in the air, the dogs are offered ice chips, rather than a bowl of water. Dog guide handlers are best qualified to determine if long-haul travel is appropriate for their dog, not the Department of Transportation.
Accommodating Dog Guides in Passenger Cabin.
The recommendations set forth in this section impose restrictive conditions on the rights of blind passengers to travel with their dog guides. In cases when dogs are judged to be "too large" to fit in the assigned floor space, offering the option of purchasing a second seat, traveling on a later flight or having the dog travel in the cargo hold fall miserably short of the airline's statutory obligation to provide a reasonable accommodation for a passenger's dog guide..
Moreover, all but one of the examples sited in the NPRM describing conditions viewed as "creating an undue burden" for the airline are completely unwarranted. For decades, airline personnel have successfully accommodated dog guides by offering passengers an opportunity to move if they do not wish to share part of the space in front of their seat with a dog guide, voluntarily blocking the seat next to the dog guide team when extra seating is available and occasionally providing seating in a class of service other than the one the blind passenger has purchased. Such modifications have repeatedly proven to be effective with little to no disruption to cabin service. In contrast, these new regulations could easily create an undue hardship for the blind passenger by imposing severe limitations on their ability to travel with their dog guide.
The best way to ensure nondiscrimination on the basis of disability in air travel is to omit any restrictions for long-haul travel and simply to allow dog guide handlers to determine what works best for their own dog.
The Air Carrier Access Act has effectively fulfilled its original intent to prohibit discrimination in airline service for disabled persons. We strongly believe that the proposed changes would, in effect, only serve to "water down" an Act that has well served the public.
I would be very happy to provide further information regarding any of these points and to provide testimony in any forum where it might be useful.
Thank you for your attention.
For more information on this issue, please read the following:
- IAADP Objections To Proposed Amendment on Air Travel Rules
- IAADP's Letter of Public Comment to DOT Officials
Return to the IAADP homepage