Delta Airlines released information regarding revised policies concerning service and emotional support animals that fly with their companions inside the cabins of Delta planes

News Release January 23, 2018

For further information, contact

Penny Reeder, President

Guide Dog Users, Inc.

866.799.8436

https://www.guidedogusersinc.org

Guide Dog Users, Inc. finds Delta Airlines’ New Policy Regarding Service and Emotional Support Animals Particularly Burdensome for Guide Dog Users and Unlikely to Solve Problems Associated with Out-of-Control and Misbehaving animals on Planes

On Friday, January 19, Delta Airlines released information regarding revised policies concerning service and emotional support animals that fly with their companions inside the cabins of Delta planes. These new requirements are expected to go into effect on March 1. Delta explained that the new policies have been developed to assure safety for all of their passengers and on-board crew members. Guide Dog Users, Inc. (GDUI) wishes to respond to the policy changes announced by Delta.

First, our members, who depend on our guide dogs for safe, independent travel, certainly agree with Delta’s goals of assuring safety for all passengers. Like every other airline passenger, we care about safety, for ourselves — and for our guide dogs as well — – and we, too, have encountered an increasing prevalence of misbehaving and uncontrolled animals (often fraudulently identified as “emotional support animals” or “comfort animals” by their owners in airports and on planes. These experiences have frequently been unpleasant, and sometimes have even compromised our safety and that of our guide dogs. We, too, believe it is our right to expect the planes on which we fly to be safe, non-threatening environments.

Delta’s new requirements, however, would represent significant burdens for us as people who are blind who have been permitted for decades to travel on public conveyances and in public venues with our guide dogs in the lead without onerous paperwork requirements. A requirement that we supply current vaccination records, for our guide dogs, online, 48 hours in advance of the first flight we take in any given year, and that we certify the airline’s possession of these records upon check-in for every flight is especially burdensome, as we will no longer be able to take advantage of curb-side or kiosk check-in, we may need to be separated from traveling companions, and the whole check-in process is likely to require longer lines and more time than would be the case for people traveling without guide dogs.

In addition, the new requirements represent logistical problems which we wonder how Delta would address, e.g., when during the course of long-distance travel we are unexpectedly transferred to a Delta plane for which we had no reservations and fur which we have not submitted the required documentation, or if we are traveling on a Sunday or holiday when our vets cannot be reached, or in the all-too-likely circumstance that the airline cannot locate or access the forms we had already submitted.

We are skeptical that requiring submission of vaccination records and in the case of emotional support animals some kind of certification that the animals have been trained to behave well in public will actually reduce the incidence of ill-behaved and uncontrolled animals onboard planes. In our experience, the unfortunate consequences of traveling with uncontrolled animals have resulted, not because of disease or lack of vaccinations, but rather because misbehaving animals have not been trained for exposure to noisy airports or crowded planes, and their owners have not been able to bring them under control. Further, we are skeptical that a veterinarian’s certification that an animal that is not trained to provide service to a person with a disability has had sufficient training to behave well in public would be a valid certification. Won’t it be just as easy for a person who wants to bring his or her untrained pet along on a trip to procure the same kind of fraudulent certification of training as he or she may have already obtained online or from some disreputable source to verify a presumed disability? In short, we question how these invasive paperwork requirements will actually address the safety concerns that we share with the airline, or resolve the problems that occur onboard because of misbehaving, uncontrolled animals. Yet, we are sure – because of our own experiences as people who are blind that the new paperwork requirements may well be extraordinarily inconvenient for us, since some of us may encounter significant difficulties with online submission of paperwork which may not even be accessible to our assistive technologies; since it will take us longer to get through the check-in process; and we will have to give up the convenience of curbside or kiosk check-in and the comfort of managing the whole check-in process in the company of travel companions.

The Air Carrier Access Act of 1986, which is the legislation that guarantees our right as guide and service animal users to fly in the company of our well trained and well cared for dogs, prohibits discrimination on the basis of disability. We suggest that imposing these exceptionally burdensome and unnecessary regulations, which we believe have little likelihood of resolving the problems of misbehaving, uncontrolled animals on planes, may represent discrimination against us on exactly the basis of our disabilities.

It is clear to us that Delta’s intentions are good. It is equally clear to us that the solutions which Delta proposes are unlikely to remedy the problems associated with ill-behaved and uncontrolled animals on planes, and further, that the new requirements are especially burdensome for guide dog users.

We have shared our concerns with the Aviation Consumer Protection Division at the U.S. Department of Transportation (DOT) which implements the ACAA. We look forward to sharing our concerns and offering advice and commentary on new ACAA regulations which the DOT will propose later this year in a notice of Proposed Rule Making (NPRM). The DOT has indicated that they will begin accepting comments on proposed regulations as soon as July. We believe that our collective experience as guide dog handlers and frequent flyers equips us with the kind of practical knowledge that will allow us to participate constructively in discussions that will lead to solutions, and we look forward to our involvement, along with other disability advocacy organizations, in The Department of Transportation’s upcoming rule-making process. Meanwhile, we urge our members to share their concerns with Delta and the Aviation Consumer Protection Division at the U.S. Department of Transportation https://airconsumer.dot.gov/escomplaint/ConsumerForm.cfm, and we hope and expect that Delta will take our concerns into account before they implement these exceptionally burdensome requirements for guide dog users in March.

Guide Dog Users Inc., (GDUI), is the leading membership-driven organization of guide dog handlers in the world. Members, most of whom are blind or visually impaired, rely on guide dogs for independence and safety. GDUI strives to promote civil rights and enhance the quality of life for working guide dog teams. Drawing on the experiences and varied knowledge of its members, GDUI provides peer support, advocacy and information to guide dog users. In addition, GDUI works with public entities, private businesses and individuals to ensure that guide dog users enjoy the same rights to travel, employment, housing, and participation in all aspects of daily life that people without disabilities enjoy. The collective knowledge and experience of GDUI’s members drives constructive dialogue, breaking down barriers, and opening doors for men and women who live and work proudly and independently partnered with well-trained guide dogs. GDUI is an affiliate of the American Council of the Blind (ACB).

Delta Airlines’ Policy: https://www.united.com/web/en-US/content/travel/specialneeds/disabilities/assistance_animals.aspx

Guide Dog Users, Inc. Welcomes United Airlines’ Unchanged Policies Regarding Guide and Service Animals, Urges Other Airlines to Follow Suit

February 5, 2018

For further information, contact Penny Reeder, President

Guide Dog Users, Inc.

866.799.8436

mailto:President@GuideDogUsersInc.org

https://www.guidedogusersinc.org

On Thursday, February 1, 2018, United Airlines announced new policies regarding emotional support animals that fly with their owners inside cabins on United planes. Like Delta Airlines, which, two weeks ago, announced policy changes regarding requirements for animals that accompany their owners onboard planes, United attributes the need to revise their policies to dramatically increasing numbers of people who, claiming disability or anxiety, bring dogs, cats, and other kinds of animals onboard, and associated increases in the number of incidents involving badly behaved and uncontrolled animals. Both airlines are motivated by concerns for the safety of all their passengers and their crews. As frequent flyers ourselves, Guide Dog Users, Inc. (GDUI) members are also concerned about our safety onboard aircraft, and additionally about the safety and welfare of our guide dogs.

We are not convinced that requiring annually updated vaccination records can address the behavioral issues that can make sharing a cabin or a row with a frightened or untrained dog any safer for passengers or crew members, but, like anyone else who flies, we don’t want ourselves – or our well-cared-for guide dogs — to be exposed to communicable diseases. We welcome United’s insistence upon health and behavioral certification for animals ostensibly brought onboard to provide emotional support or comfort, as well as verification of pet owners’ needs for this kind of assistance from reputable, licensed professional sources. We are hopeful that expanded requirements for certification of behavioral training for animals whose purpose is to provide emotional support will decrease the numbers of misbehaving and out-of-control animals onboard planes, making us – and our guide dogs – safer, and flying a more comfortable experience for everyone.

While Guide Dog Users, Inc. has criticized Delta’s expanded requirements for people with disabilities who need to bring their guide and service animals onboard Delta flights, GDUI applauds United Airlines’ decision to make new requirements for health certificates and good behavior certification applicable only to emotional support animals who often receive limited training at best and for whom there may not be a licensed authority to guarantee good health or up-to-date vaccinations.

GDUI is gratified to know that United Airlines seems to understand that the rigorous training our guide and service animals receive, as well as their daily exposure to community environments and public venues, makes it unlikely for our dogs’ behavioral or health status to pose risks to the safety of passengers or crew members onboard United planes. Further, our reliance on guide and service dogs for independence and personal safety makes maintaining our dogs’ good health, appropriate behavior, and proper grooming essential obligations for every guide and service animal user.

An annual duty for guide dog users to provide vaccination records to Delta and further to confirm with Delta personnel the airline’s possession of the certification every time we want to check into a flight would be particularly burdensome for guide dog users, who would no longer be able to check in via smart phone, kiosk, or at curbside, who would need to spend extra time in line while waiting to confirm paperwork receipt, and who would likely be separated from traveling companions during the process. In addition, Delta’s expanded requirements could easily necessitate extra expenses for people who might not have internet access and would therefore have to travel to an airport 48 hours in advance of a flight in order to submit vaccination records, as well as extra charges which, we have already heard from members, that some vets are charging for submitting the required paperwork.

We have no way of predicting whether or not requiring certification of training for emotional support animals will reduce the number of misbehaving dogs on flights. Certainly, the reliability of the certifying authority will make a difference. We are hopeful that the additional requirement for training certification will convince pet owners whose dogs may be unfamiliar with conditions like noisy airports and crowded planes to leave their pets at home or to contain them inside appropriate carriers to prevent their roaming through aircraft and threatening the safety of other passengers and crew.

No case can be made, however, for requiring additional or early submission of medical records for our guide dogs, since maintaining their good health is an essential prerequisites for the life-saving services they provide for us and for their near-universal acceptance in public venues. We urge Delta to reconsider these onerous requirements for those of us who need to fly with our guide and service animals, not only because of the inconvenience and extra expenses they represent, but also because, as a class of people who are blind, we feel that these rules single us out as targets of unlawful discrimination. At least equally important, requiring guide and service dog users to submit vaccination records online in advance and in person at a Delta ticket counter is unlikely to solve any of the problems associated with misbehaving and uncontrolled animals onboard planes.

We are told by United, Delta and other airlines that the number of animals air carriers are expected, under the direction of the Air Carrier Access Act (ACAA), to transport has nearly doubled just in the last twelve months , and as the number of incidents that have compromised the safety of passengers and crew members has increased, we understand why the airlines are re-evaluating their policies and requirements. Because a patchwork of sundry requirements for variously defined populations is bound to be confusing at best, and such a bureaucratic burden that making airline reservations may become a nearly impossible task, we urge all U. S. air carriers to work in coalition with one another, with membership organizations like ours who can speak on behalf of guide dog users, and with the U. S. Department of Transportation, which will release a Notice of Proposed Rule Making (NPRM) for the ACAA in July, to harmonize the policies and procedures which serve to deter passengers from bringing animals which they cannot control and whose appropriate behavior they cannot assure onboard planes. GDUI is eager to assist in this process. We urge Delta and other airlines to take a page from United’s planning book which recognizes the excellent training, appropriate behavior, and well-maintained health of guide dogs which we and members of the general public have depended upon for decades, while developing requirements for less well-trained dogs and comfort animals that can assure onboard safety for all of us.

GDUI Advocacy Committee Responds to United Airlines Announced Policy Concerning Animals Onboard Planes

Guide Dog Users Incorporated (GDUI) has been reviewing the recent decision by Delta Airlines to further insure the well-being of its passengers against a dramatic increase in the amount of service and emotional support animals who have been poorly behaved, and flying in their cabins. We very much agree with the desire of Delta Airlines to insure its flights are safe and accessible to all who choose to fly on Delta. However, we find the requirements’ applicability to all service and emotional support animals to be most distressing, especially for guide dog users whose dogs have in large measure never been a hazard or otherwise problematic for airlines.

GDUI applauds the recent decision by United Airlines to follow the lead of Delta as applied to emotional support animals, but not to trained service animals. United’s new policy recognizes that, unlike emotional support animals, guide dogs and other types of service animals require extensive training and socialization in order to successfully perform their duties in public settings. The United policy honors the traditional utilization of air travel by people with disabilities working with well-trained service animals without placing undue and needless burdens upon them. GDUI will issue further commentary as we work with others to assist airlines in developing the best possible policies that facilitate the use of service and emotional support animals without inconveniencing the flying public or those who legitimately need the assistance of their animals.

Charles H. Crawford, Chair

Advocacy and Legislative Committee

Guide Dog Users, Inc

Make your views known to the U. S. Department of Transportation here: https://airconsumer.dot.gov/escomplaint/ConsumerForm.cfm