International Association of
Assistance Dog Partners

IAADP Position Statement (Short) - 4 Positions

IAADP Replies to the 3 Questions from the NPRM & Comments on another Problem with the definition. If you want a more in depth explanation of our positions, please read IAADP’s Public Comment. To support one or more of these positions, please submit a comment on the Public Comment website at this Link: http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=090000648062a604

( 1 ) Question Nine: MINIMAL PROTECTION

IAADP’s Answer: We urge the DOJ to remove the phrase “minimal protection “ as a Task Example from the new definition of a Service Animal! Fifteen years of misinterpretation s of this task example, with a number of protection dog trainers and disabled consumers claiming it sanctions attack or aggression training for service dogs under the ADA, is enough!

( 2 ) Question Ten: OTHER SPECIES

IAADP’s Answer: We ask the Department to consider establishing guidelines that would limit the use of other species only to animals who can be trained to meet the same standards for behavior and training that assistance dogs must meet to qualify for public access.

( 3 ) Question Eleven: A SIZE OR WEIGHT LIMIT

IAADP’s Answer: We oppose a Size or Weight limitation on common domestic animals like Assistance Dogs! It would discriminate against disabled persons whose weight, height and/or the severity of their mobility impairment necessitates that they work with a dog of a breed of sufficient size and strength to prevent falls or perform other tasks without injury to the dog.

( 4 ) Problem: The DO WORK phrase in the Definition

IAADP’s Position: We urge the Department to eliminate the “do work” phrase in the proposed Definition. Not only is it redundant, the example given of work in the NPRM, "grounding," will lead to years of problems, as it undermines the Department's goal of maintaining a clear distinction between specially trained service animals and a pet whose mere presence can provide emotional support, companionship or therapeutic benefits.

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