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Date Posted: 08:32:56 02/16/05 Wed
Author: Karen
Subject: DOT change may make travel with service dogs harder

PLEASE CROSSPOST!
Also there is more information on the link that needs to be addressed (how to send letters, where to, etc. But here is the jist of it and the link for more info and what to do.



Karen Peak
West Wind Dog Training

http://www.iaadp.org/calltoaction/

IAADP Needs Your Help!
The Department of Transportation's Notice of Proposed Rule Making (NPRM) contains an alarming change to the regulatory language about seating accommodations for assistance dog partners. The proposed rule grants airlines the right to require a passenger with an assistance dog to purchase a second ticket if the canine assistant is not small enough to fit in the floor space directly in front of the passenger's seat. Alternatively, airlines may require the passenger to ship the dog in cargo or wait for a later flight.

IAADP does not believe this proposed policy is "a reasonable accommodation" for those of us traveling with assistance dogs. It penalizes disabled people working with large dogs for physical support, guidance or wheelchair pulling. Even smaller dogs wearing backpacks containing medical supplies and equipment required by the disabled passenger may not fit into this space.

We believe this inclusion of new regulatory language would violate the spirit of the Air Carrier Access Act, which Congress passed to ensure the airlines would increase the accessibility of air travel to the disabled population.

Purchasing a second seat is not a viable option since the additional costs would exclude most disabled people with large dogs from traveling by air. It would place an undue financial burden on them. A frequently cited statistic is that 70% of the 54 million Americans with disabilities are unemployed and more than 40% rely on the federal welfare program. Disabled Americans constitute the most economically deprived segment of the population. Finally, if a flight is fully booked, how would being charged for a second seat solve the problem?
Traveling on a later flight does not guarantee the issue will be resolved, since the same circumstances may exist on the later flight. The prospect of being forced to delay the trip, missing connections, pick up times and appointments would be a huge disincentive to air travel.
Shipping the assistance dog in cargo due to the risk of trauma or loss is an option unacceptable to IAADP assistance dog partner members. Such a separation was declared to be a violation of the Americans with Disabilities Act by the Ninth Circuit Court of Appeals in the Crowder case against the state of Hawaii.
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. IAADP believes the DOT's NPRM language would foster an adversarial relationship between disabled passengers with large
assistance dogs and the airlines.

IAADP would like to see the following language substituted by DOT as advice to in-flight crews and counter agents:

"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."

Using this approach to the issue of the assistance dog unable to fit within the floor space in front of the disabled passenger's seat would not be a financial burden for the airlines or an
inconvenience to other passengers.

Please Read:

Why we urgently request a Letter from YOU during the Public Comment period on DOT's proposed regulations BEFORE March 4, 2005 deadline
Official Letter of Public Comment from IAADP ( in depth analysis of several problems in the NPRM that assistance dog partners may want to comment on)
SAMPLE Letter ......to make your job a bit easier.
Instructions on how to Submit Your Comment

(the please read links are on this page: http://www.iaadp.org/calltoaction/)


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