International Association of
Assistance Dog Partners

U.S. Department of Transportation
1200 New Jersey Avenue, SE.,
West Building Ground Floor, Room W12-140
Washington DC 20590

DOCKET - OST - 2011 - 0182


        The International Association of Assistance Dog Partners (IAADP) is a nonprofit organization founded in 1993 to represent the interests of disabled persons who work with guide, hearing and service dogs.  On behalf of nearly 3000 members, IAADP welcomes this opportunity to discuss certain issues related to Service Animal Relief Areas on which the U.S. Department of Transportation (DOT) seeks comment.

( 1 )     The most important issue for our community in the Notice of Proposed Rule Making is the question posed by the DOT on where to locate service animal relief areas.  The DOT seeks comments on whether service animal relief areas should be located inside or outside “the sterile area.”   The sterile area is understood to be the secure area between the TSA screening checkpoints and the gate area where passengers board or deplane the aircraft.
         IAADP thanks the DOT for this rule making proposal which seeks to address the fact that time and distance to service animal relief areas located outside the sterile area pose barriers for disabled passengers.

        In May 2008, the DOT’s Final Rule on Part 382 was published in the Federal Register. It required airlines work with airports to establish service animal relief areas for disabled passengers.
        IAADP and other members of the Coalition of Assistance Dog Organizations (CADO) developed a List of Recommendations titled “CADO Guidelines for Service Animal Relief Areas at Airports.”  Our goal was to enable airports to build service animal relief areas that could be readily utilized by the estimated 30,000 disabled Americans partnered with guide, hearing and service dogs.  CADO members include consumer organizations, IAADP and Guide Dog Users, Inc., and the organizations representing nonprofit assistance dog training programs, Assistance Dogs International and the Council of U.S. Dog Guide Schools. 
        We subsequently shared the CADO Guidelines with the DOT, the association representing airport managers, fifty major airports and other entities.   We furnished materials so our respective members could contact nearby airports to alert them to the May 2009 regulatory deadline for service animal relief areas and to share CADO’s Guidelines.  Our top recommendation was that service animal relief areas be located in the sterile area.  CADO’s guidelines also recommended airports and airlines consult with assistance dog partners and programs in addition to the TSA to ensure the design of the outdoor service animal relief area would meet the needs of passengers with different disabilities and their assistance dogs. 
        To the best of our knowledge, almost all airports decided to locate the relief area outside the sterile area on the landside of airports, some a good distance away from the terminal to the severe disappointment of all involved in this advocacy initiative. 

       We would like to raise awareness of why locating relief areas inside the sterile area is important to our community.
        It is extremely distressing to have your assistance dog indicate he or she suddenly needs to eliminate on the way to the gate or when changing planes or immediately after the plane arrives at your destination.  Any dog can experience a digestive upset or be unnerved by air turbulence on a flight, urgently necessitating a trip outdoors to prevent “an accident” and alleviate the dog’s cramps.  This problem can be compounded by the fact that wheelchair users often have to wait 45 minutes or more till all the passengers have deplaned and until their wheelchair is brought up from the cargo hold and until someone finally comes with an aisle chair for transferring.  Passengers who are blind report there is often a long wait for an escort.  Those using a walker or crutches have to make their way very slowly through the airport, while those with medical conditions causing shortness of breath, dizziness, pain or fatigue will also find it to be grueling to try to reach a service animal relief area that is located outside the sterile area.  After leaving the terminal to find the service animal relief area on what is called the “landside” of the airport, disabled passengers with a flight to catch will need to get in line to go through the TSA screening checkpoint again.  This entire process can be so time consuming, returning to the gate area in time to make the flight may not be possible for many teams.  Any of us can end up in this predicament when we fly, since illness, air turbulence, thunderstorms and other events highly stressful for many assistance dogs are factors beyond our control.  
        In addition, very young dogs, elderly dogs and assistance dogs on their first flight will need to eliminate more often than seasoned travelers in their prime, so taking the dog out for relief purposes is a prudent measure for their disabled partners to ensure the public is not inconvenienced by what we refer to as “an accident” while we are in transit. 
        It is with these considerations in mind that IAADP urges the DOT to require a minimum of one service animal relief area per terminal located inside the sterile area to significantly reduce the time and distance for disabled passengers whose assistance dogs need to make use of the service animal relief area.  In very large terminals with more than one concourse where gates may be well over a quarter mile apart, we hope the DOT will require a centrally located relief area inside the sterile area or if that is not possible for logistical reasons, the airport could build two service animal relief areas inside the sterile area, one at either end of the terminal to ensure time and distance do not pose barriers for disabled passengers traveling with canine assistants.  These relief areas need to be located outdoors on the sterile side of the airport, something the TSA discussed in its Guidelines issued in May 2011.
        IAADP believes service animal relief areas located inside the sterile area would best serve the needs of the vast majority of disabled passengers with assistance dogs when on the way to the gate, changing planes or during a stopover and immediately after arriving at their destination before passengers have to collect their luggage.  Few of us could manage all our luggage and a trip to a service animal relief area located outside the terminal on the “landside,” especially if traveling alone.  Airports which only built one service animal relief area to serve disabled passengers at airports with two to six terminals, thinking the fact it is rarely used indicates there is no need for additional relief areas, hopefully will take a second look at this problematic situation.
( 2 )   After careful consideration of information provided in the NPRM on the need for coordination with the TSA and each airport’s site specific Airline Security Program if relief areas are located in the sterile area, it seems prudent for the DOT to require the provisions of this Rule to apply to U.S. and foreign airlines in Part 382 to ensure no conflict exists which might negatively impact the delivery of services to disabled passengers who ask an airline employee for directions or an escort to a service animal relief area located inside the sterile area.      

( 3 )      Ideally all airline personnel would receive training as to the location of the service animal relief areas at every destination and so would all airport employees, enabling any of them give directions to disabled passengers with a service animal.  Recognizing the inherent difficulties and the huge price tag that could be attached to a formal effort to educate the entire workforce, IAADP is very much in favor of the DOT requiring airports to put up a sufficient number of signs to guide disabled passengers and escorts to service animal relief areas without getting lost.  
          We urge the DOT to require airports to adopt and utilize consistent signage throughout the United States.  These signs should prominently feature a symbol meaning “Service Animal.”  We envision this symbol as comparable to what has become the universally recognized symbol for “disabled,” which incorporates a wheelchair motif, featured on handicapped parking signs, the doors of accessible restrooms for the disabled and on other items.  We suggest adoption of a stylized representation of an assistance dog or a silhouette of a dog’s head since airports fall under the jurisdiction of the Americans With Disabilities Act, which has an updated service animal definition that limits the species which can be labeled a service animal to dogs, as of March 15, 2011.  Dogs are also the predominant species traveling on airlines as service animals.
        IAADP believes the use of the same symbol for “Service Animal” at all airports in the USA could be considered a reasonable accommodation under the Americans With Disabilities Act for persons who have a learning disability or cognitive impairment that makes reading a sign printed in English or any other language impossible, while still being able to recognize and respond to a pictorial representation of something important to that individual.  This same symbol would be helpful to persons who are illiterate due to lack of education and escorts not yet fluent in reading English as it is not their native language.  As a bonus, the eye catching nature of the symbol could potentially be beneficial to airports and airlines in educating their employees, prompting those who are curious to ask a colleague what it stands for, thus familiarizing many of them with the existence of service animal relief areas.  

 ( 4 )   In reply to the request for comments on whether airport websites should have a map of the airport that shows the location of service animal relief areas, indicating whether they are located
inside or outside the sterile area, IAADP finds the lack of such information on airport websites to be a regrettable oversight.  We recently published an article in our newsletter by an IAADP member who contacted an airport seeking information on the location of their service animal relief areas.  She let us know the airport was willing to add this data to their website map at her suggestion once the desirability of such information for trip planning purposes had been made clear to the individual to whom she spoke at that airport.  Rather than an ongoing piecemeal approach, leaving it up to disabled persons to persuade various airports of the value of showing service animal relief areas on their website map of the airport and in directories and literature with a map, IAADP asks the DOT to require all airports to make this information available to persons with disabilities and families with disabled children who may travel with a service animal and other interested parties.  It would also be a valuable resource for airlines which have to furnish directions or escorts to the service animal relief area upon request from a disabled passenger, at the 368 airports in the USA with more than 10,000 deplanings a year covered by this NPRM.
( 5 )    IAADP is very much in favor of this Rule empowering the DOT to adopt requirements regarding the design of service animal relief areas, including the dimensions, materials used and maintenance for relief areas, but we suggest the DOT refrain from detailing all the specifics of such requirements in the Rule itself, retaining the right to be flexible on specifics when the language for the Rule is finalized.  This will allow for permitting airports to try new materials that are climate specific or cleanup specific which may be developed in the future and recommended by those with expertise such as, but not limited to, the TSA relief area expert in the canine division, without going through the long drawn out process for amending the Rule.

        Maintenance for relief areas should include the airport operator assigning someone to inspect and if needed, to pick up droppings in the relief area three times a day.  This is especially important for relief areas that do not permit wheelchair users to get close enough to the place where the dog eliminates to pick up after the dog or for passengers whose disability prevents this courtesy due to dizziness, pain or risk of a fall from loss of balance or some other disability related issue.

       The Coalition of Assistance Dog Organizations (CADO) Guidelines for Service Animal Relief Areas at Airports, included below the photos in this document, provide additional input from our community as to the materials to be used, desired minimum dimensions, provision of a supply of pickup bags, a disposal receptacle and so forth.

       IAADP opposes the installation of indoor service animal relief areas.  We have received complaints from IAADP members taken to such sites in airports because their dogs refused to eliminate indoors.
       We ask the DOT to follow TSA guidelines issued in May 2011 for establishing relief areas outdoors, accessed from the sterile area.  In doing so, we recognize that most assistance dogs are deliberately trained to never go to the bathroom indoors.  Since Nov. 1996, the DOT guidance document has mandated such training by informing passengers that if a dog urinates or defecates in the airport or plane cabin, the airline does not have to treat the animal as a service animal, as such conduct would demonstrate the dog has not been properly trained to behave as a service animal in public, even though it may perform an assistive function.  This remains the DOT’s position in the most recent Guidance document in the Final Rule on Part 382, published in May 2008.
        Taking an assistance dog team to an indoor area for relief purposes sets up the vast majority of teams for failure.  If the person is so worried about missing the flight, he or she commands the dog to eliminate indoors, it will cause dogs unaccustomed to indoor relief to experience a tremendous amount of stress.  Pressuring the dog will be futile in most cases.  If the disabled person refuses to pressure the dog, realizing it is a waste of time, the dilemma of what to do next and disappointment at being escorted to such an unsuitable place for relief purposes is no less upsetting.  
         We cannot count on all airport operators to understand this.  See the photos below of the indoor relief area that an IAADP member was taken to at Seattle’s SEA-TAC airport, for a graphic look at the current problem of airports having no standards to go by on design, dimensions, materials and location.
          In closing, IAADP would like to commend the U. S. Department of Transportation for this
rule making initiative to improve air travel for passengers with disabilities.

respectfully submitted,

Toni Eames, M.S., President
International Association of
    Assistance Dog Partners

dog cage

CADO Guidelines for Service Animal Relief Areas at Airports
1.  Service animal relief areas should be established within the secured perimeter.
2.  The location of service animal relief areas should be negotiated between airlines, airport operators, assistance dog training programs and assistance dog partners. Representatives of TSA should be asked to participate in these discussions.
3.  A minimum area of 10 feet by 10 feet should be set aside for each relief area. If space permits a larger area should be designated.
4.  Grass or other natural surfaces are preferred. Additional surfaces may be wood chips or gravel.
5.  Every service animal relief area must be accessible for physically disabled individuals using wheelchairs or other mobility devices.
6.  The service animal relief area must be maintained by airlines and/or airport operators.
7.  All service animal relief areas should have bags for pick up, pooper scoopers and trash receptacles.
8.  Service animal relief areas should be fenced in with gates wide enough to provide wheelchair access.
9.  Escort service staff must be trained about these requirements and notified of the mandate to provide escort service to and from the service animal relief area for disabled passengers accompanied by assistance dogs.
10.  Other airline staff, such as Complaint Resolution Officials, must be trained about these requirements and know the location of designated service animal relief areas.


Below is the language used in the 2008 Final Rule published in the Federal Register,
Part II, Department of Transportation, 14 CFR Part 382Nondiscrimination on the Basis of Disability in Air Travel; Final Rule,Page 39             382.51
Paragraph only:One new requirement at U.S. airports is to provide, in cooperation with the airport operator, animal relief areas for service animals that accompany passengers who are departing, arriving, or connecting at the facility.

 Photo Examples of Service Animal Relief Areas from Airports in Phoenix and San Diego

animal relief

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