FROM: Assistance International, North America TO: U.S. Department of Transportation Office of the Secretary RE: 14 CFR Part 382 [Docket No. DOT-OST-2018-0068] RIN No. 2105-AE63 Traveling by Air with Service Animals Notice of Proposed Rulemaking (NPRM) Request for Comments Table of Contents Introduction Assistance Dogs International 1 ADI North America 1 Comments Capuchin Monkeys 2 Limit Species of Service Animals to Dogs 2 Breed or Type Restrictions 2 Allow Airlines to Assess Animal’s Behavior 2 Exclude Emotional Support Animals from DOT’s ACAA Definition of 2 Align ACAA with ADA 2 Regulate ESAs Distinctly from Service Animals 3 Impact on Individuals with Using ESAs 3 Likelihood of ESA Users Flying Less If ESAs Banned 3 Should DOT Recognize an Option of ESAs Trained to Do Work Or Perform a Task 3 Are ESAs More Likely to Misbehave in Comparison to Traditional Service Animals Because They Have Not Been Trained to Mitigate a 3 Would Stricter Documentation for ESA Users Decrease Fraud 3

How Would Limiting ESAs to Dogs and Cats Impact Individuals With Disabilities Who Rely On Other Species 4 Impact of Not Recognizing Cats as ESAs 4 ESAs in FAA-Approved In-Cabin Carriers 4 Limiting ESAs to Those That Fit in Carriers 4 Limiting ESAs to One Per Passenger 4 Size of Service Animal 4 Limit Number of Service Animals Traveling with A Single Individual 5 Definition of a Service Handler 6 Impact of Excluding Third Party as Allowed Handler 6 Control of Service Animal 6 Carriers for ESAs 6 Forms – Should They Be Universal 7 Are There Existing Forms That Should Be Used 7 Combine Behavior and Training Attestation Form with Relief Attestation Form 7 Should Behavior and Training Attestation Form Be Required 8 Is the Behavior and Training Attestation Form Effective 8 Ways to Reduce the Burden of the DOT Behavior and Training Form On Passengers with Disabilities 8 Should Airlines Be Allowed to Require the Form Each Time a Service Animal User Travels 8 Preferable Medium 8 Privacy Concerns 8 Is This Form Helpful to Airlines in Determining Animal’s Training 8 Does Form Adequately Educate Passengers on How a Service Animal Is Expected to Behave and Seriousness of Fraud 9 Should DOT Allow Airlines to Require Only ESA Users to Complete Behavior and Training Attestation Form 9

Content and Layout of Form 9 DOT Service Animal Health Form 9 Is One Year Too Long or Too Short for Vaccination Form To Be Valid 10 Form as Evidence Animal Has Received Vaccine 10 Form as Evidence – Aggression 10 Should the DOT Permit Airlines, As A Condition of Travel, To Require The Service Animal Health Form 10 Would the Form Be Effective in Ensuring That the Traveling Public Would Not Contract Rabies from Service Animals Should They Be Bitten 11 Health Form – Veterinarian’s Description of Animal, Photo ID 11 Health Form – Content and Layout 11 Service Animal Relief Attestation Form 11 Adequate Proof 11 Content and Layout 11 Prohibition of Requiring Forms Prior to Travel Date 11 Allowing Airlines to Request Form 12 Are Forms Best Way to Collect Data 12 One Hour Early Check In 12

Assistance Dogs International Assistance Dogs International (ADI) is a worldwide coalition of non-profit programs that train and place Assistance Dogs. Founded in 1986, ADI is the leading authority in the industry. The objectives of ADI are to:  Establish and promote standards of excellence in all areas of assistance dog acquisition, training and partnership  Facilitate communication and learning President George H.W. Bush and his Service Dog among member programs Sully with President Bill Clinton

 Educate the public to the benefits of America’s Vet Dogs, St. Smithtown, NY Assistance Dogs and ADI membership. ADI North America ADI North America (ADI, NA) consists of 73 Assistance organizations: United States – 65 Canada – 8 ADI, NA Service Dogs teams currently active in North America – 17,504 ADI, NA member clients comprise the majority of individuals using service dogs including those using air carriers. ADI, NA appreciates this opportunity to share its expertise regulations pertaining to air travel by animals in the airplane cabin.

1

Capuchin Monkeys: No ADI, NA opposes airlines allowing the transport of closed-colony capuchin monkeys in carriers with a qualified trainer. Dogs are the main species trained as service animals. They are a domesticated animal that presents a natural temperament to work with humans. Capuchin monkeys are wild animals, and therefore, not suited to training as service animals. Whether or not they are from a closed colony, capuchin monkeys should not be forced into the life of a domestic animal.

Limit Species of Service Animal to Dogs: Yes, Agree with DOT ADI, NA agrees that service animals should be limited to dogs. Dogs have hundreds of years of history as domesticated animals that work successfully with humans. The vast majority of service animals are dogs. Dogs have a natural temperament to work successfully with humans. Dogs are typically sized so as to fit at the feet of an airline passenger.

Breed or Type Restrictions: Yes, Agree with DOT ADI, NA agrees that there should not be breed or type restrictions to service dogs. The dog’s training and history of treatment determine its behavior in the air travel environment, not its breed or physical traits.

Allow Airlines to Assess Animal’s Behavior: Yes, Agree with DOT Airline personnel are in the best position to assess the individual animal’s behavior in the airport environment. Many behaviors indicating or preceding aggression are obvious, such as growling, snapping and lunging. The main cause of aggression is fear; therefore, aggression may not present prior to animals being in an environment that scares or stresses them.

ADI, NA members remain eager to educate the airline industry on animal behavior and health assessment so that airline personnel can adequately ensure that aggressive animals are not transported on aircraft.

Exclude Emotional Support Animals from DOT’s ACAA Definition of Service Animal: Yes, Agree with DOT ESAs are not required to have any training. The majority of problems in air travel regarding animals have arisen from ESAs due to the fact their lack of training.

Align ACAA ADA: Yes, Agree with DOT ADI, NA agrees that ACAA should use the same definition of service animal at the DOJ’s regulation of service animals under its rules implementing the ADA.

The Assistance Dog industry puts tremendous time and effort into maintaining high standards of training and behavior for its service dogs. We place an enormous emphasis on training in public. Guide Dogs have a 100 year history of public work and other types of Service Dogs have been working in public for 50 years since the 1970’s, all with great success in numerous public venues including air travel.

ESAs, conversely, are not required to have any training, either in working or performing tasks, nor public behavior. Thus, public environments, specifically stressful ones, such as air travel,

2 prove overwhelming to ESAs resulting in disruptive behavior that can include aggression to people or other animals and damage to property.

Regulate ESAs Distinctly from Service Animals – No ADA, NA holds that ESAs’ lack of training is what makes them problematic in air travel. Therefore, we feel they should be treated as . There is no difference between an ESA and a , apart from the details of the owner. An ESA is a pet owned by an individual who derives a benefit from the animal. The animal itself is the same as a pet.

Impact on Individuals with Disabilities Using ESAs If the ESA is able to travel as a pet, the owner retains the opportunity to travel with the ESA. They no longer get the benefit of free airfare for the animal.

Likelihood of ESA users flying less if ESAs banned No comment.

Should DOT Recognize an Option of ESAs Trained to Do Work or Perform a Task – No ESAs would still lack the training necessary to behave well in public, especially in the stressful air travel environment. Service animals have two jobs: mitigate the person’s disability through tasks and behave well in public. Otherwise, dogs that intuitively picked up on helping their disabled owners, such as deaf individual’s dogs naturally indicating sounds, would qualify as Hearing Dogs. And they don’t. Because they still need the public work training. Typically, if not all of the time, the public work training is more challenging for service dogs than the assistive behaviors.

Are ESAs More Likely to Misbehave in Comparison to Traditional Service Animals Because They Have Not Been Trained to Mitigate a Disability – Yes While the lack of public work training is the main factor in ESAs’ increased potential to misbehave in public relative to traditional service animals, ESAs’ lack of task training also contributes. Training overall sets up a system of expectations and structure for an animal. The relationship becomes that of the human being the leader and the dog seeking the leader’s approval, demonstrated in rewards, such as treats, praise, tactile (petting) and other “payoff’s”.

An ESA, by definition, benefits its partner by its mere existence. This can include many variations in the human-animal relationship. While its partner may derive benefit from the ESAs companionship, this is inadequate to succeed in air travel.

Would Stricter Documentation for ESA users Be Effective in Decreasing Fraud by Businesses Seeking to Profit by Guaranteeing ESA Documentation – N/A Lack of training is the issue concerning ESAs. Documentation regarding fraudulent ESAs or Service Animals, should ESAs remain classified as Service Animals, is a separate issue. If ESAs are no longer classified as Service Animals, their documentation becomes irrelevant.

Currently, their documentation is also irrelevant because their lack of training is the cause of the behavior problems. The cause of their behavior problems is not whether they are really an ESA or not, regardless of documentation.

3

How Would Limiting ESAs to Dogs and Cats Impact Individuals with Disabilities Who Rely on Other Species of Animals to Accommodate Their Disability – N/A As DOT stated, this is a balance of individual accommodation and general public safety. In the case of species other than dogs or cats, there remains no requirement for training of any kind. There is also no requirement that an ESA even be a domesticated animal. There is no regard for the safety of the flying public or the airline industry or legitimate service animals. Therefore, it is not reasonable to accommodate individuals seeking to travel with ESAs of species other than dogs or cats. Although the impact can be imagined as discontent, it does not outweigh the safety concerns. It is similar to saying if a passenger with a disability received emotional support from smoking, it would not be a reasonable accommodation due to the safety impact on other passengers, the airline staff and trained service animals.

Impact of Not Recognizing Cats as ESAs – N/A Cats, while comforting, are not required to be trained to be ESAs, just like all animals that are ESAs. Therefore, cats should be treated as pets by the airline industry and the DOT.

ESAs in FAA-approved in-cabin Carriers – N/A ESAs in carriers should be treated as pets. They are not required to be trained. They are not prepared to cope with the stress of air travel. Allowing a carrier to be opened to touch the animal presents the same risk as opening a carrier containing a pet. Because an ESA is a pet – it is just owned by someone with a disability who feels comforted by its presence. The DOT should allow the airlines to apply their rules regarding traveling with pets in carriers to ESAs in carriers.

We recommend that carriers be used that allow a passenger traveling with an ESA to touch it without opening the carrier, such as a hole, slats or mesh.

Limiting ESAs to Those That Fit in Carriers – N/A As ADI, NA feels that ESAs should be classified as pets, they would need to be able to fit into a carrier sized consistent with FAA regulations to travel in cabin with the passenger.

Limiting ESA to One Per Passenger – NA DOT should allow the airlines to apply the same policy as they do for pets. The animal must fit in an FAA-approved in-cabin carrier. If airlines allow multiple pets to fly in one carrier, which must remain closed, then we are in agreement to apply this policy to ESAs as long as the species were also limited to the airlines’ policy on pets.

Size of Service Animal Dogs should fit into the foot space provided. Best practice for Teams from accredited Assistance Dogs International and International Federation programs is that dogs be unobtrusive and on the floor; thereby, reducing the impact on neighboring passengers.

We recommend larger breed dogs be accommodated with adjacent seats being left empty so they have double the floor space and have enough room to fit and not encroach on neighboring passengers. Where possible, bulk head seating is also a viable option. The majority of dogs

4 likely to be under 46kg (100 lbs). Dogs in the Large to Giant category should be given the adjacent floor space to ensure they are not encroaching on neighboring passengers.

Flying service/guide dogs in cargo is not a viable option as the dogs need to be with their handler in order to mitigate their disability.

We recommend a size chart (as is utilized in Canada) to inform airlines of size of the service dog and also recommend that the data also be captured online at time of reservation through the attestation documents or other process. Canada uses the chart below for service dogs traveling by air.

Service dog size classification Service dog measurements Mass Length Height Width Small < 11 kg < 56 cm < 41 cm < 18 cm Medium 12-25 kg 58-86 cm 38-53 cm 15-20 cm Large 26-39 kg 89-102 cm 53-66 cm 18-22 cm Extra-large 40-46 kg 104-117 cm 63-74 cm 20-25 cm Giant > 46 kg > 117 cm > 74 cm > 25 cm a The service dog shall be classified in size based on the largest individual measurement (mass, length, height or width).

Service dog size classification Service dog measurements Mass Length Height Width Small < 24 lb < 22 in < 16 in < 7 in Medium 25-55 lb 23-34 in 17-21 in 5-8 in Large 56-85 lb 35-40 in 22-26 in 7-9 in Extra-large 86-100 lb 41-46 in 27-30 in 8-10 in Giant > 100 lb > 46 in > 30 in > 10 in a The service dog shall be classified in size based on the largest individual measurement (mass, length, height or width).

Limit Number of Service Animals Traveling with A Single Individual to Two Animals – No, Disagree with DOT ADI, NA surveyed its member organizations asking if any of them trained more than one Service Dog for a client. All of the organizations responded that they only train a single service dog at a time for a client.

If a client has multiple disabilities, ADI, NA organizations train the single dog to perform tasks to mitigate the client’s full range of disabilities, when possible. When it is not possible, they discuss with the client which behaviors the dog can perform successfully and continue with training the single service dog to perform those tasks.

5

Furthermore, multiple ADI, NA organizations stated that even an experience trainer would have trouble safely managing two service dogs at a time in any public environment, especially those encountered in air travel.

Definition of a Service Dog Handler It makes sense to define the person as the one with a disability that the service dog is trained to help in a meaningful way.

We agree with the concept of a "safety assistant", being permitted to have control of the service dog limited to when the disabled passenger may have difficulty controlling the service dog on an aircraft (Eg.., a young child with a medical alert dog).

Impact of Excluding a Third Party as an Allowed Handler - NA The ACAA pertains to disabled passengers. The impact on third parties, such as trainers who are not traveling in the company of disabled passengers falls outside of the scope of the ACAA and its accompanying regulations.

Service Animal Must Be Under Service Animal User’s Constant Control – Yes, Agree with DOT The Assistance Dog industry standards set forth by Assistance Dogs International require that Assistance Dogs/Service Dogs be under the control of their user.

ADI also requires that the dog can be handed off to a third party in case of need or emergency, e.g. the user has a medical emergency and needs to be driven in an ambulance.

ADI, NA Service Dogs users with report that they successfully ask a fellow passenger to hold their dog’s leash while they use the airplane lavatory. This is currently necessary due to the small size of airplane lavatories.

In our meeting with the DOT Civil Justice Division, November 25, 2019, the small size of lavatories was discussed pertaining to this subject, as well as to accommodating someone in a wheelchair or someone who uses a support person in the lavatory. The current lavatories are too small to give many disabled passengers privacy in the lavatory when accompanied by a support person. Nor can they fit any kind of wheelchair. Nor can they fit any but the tiniest dog. While some Hearing Dogs and a few Service Dogs are small in stature, e.g. 10 pounds, most are the size of Labrador and similar breeds and can’t accompany their user to the airplane lavatory.

Carriers for ESAs, if final rule recognizes ESAs - No The Assistance Dog industry trains service animals to be under control by leash, harness or other, if necessary for animal to do its job. Carriers are not necessary and interfere with animal performing its job. Repeatedly, our industry has made the point that our providers spend a lot of time training Assistance Dogs to behave properly in public, including complex environments such as those related to air travel.

6

We feel that ESAs should be regarded as pets. Carrier policy towards pets should be applied to ESAs. If any animal that is classified as a service animal by the final rule travels on a plane, it should be properly leashed or harnessed and under the handler’s control. Otherwise, it should not be allowed to travel other than as a pet.

Forms - Should They Be Universal - Yes Should forms be used, they should be universal to reduce the discriminatory cost and time to disabled passengers traveling with Service Dogs.

Are There Existing Forms That Should Be Used In the event that the DOT elects to use forms, ADI, NA would like to collaborate with the DOT on drafting them.

Combine Behavior and Training Attestation Form with Relief Attestation Form - NA ADI, NA strongly supports the use of check boxes on reservation forms for behavior, training and relief attestation.

Should the Behavior and Training Attestation Form Be Required? – No, Disagree with DOT ADI, NA strongly feels that that DOT nor the airlines should require specific forms.

ADI, NA approves of passengers checking a box during the reservation process that says, “I certify my dog is a trained service dog and will behave appropriately”. We feel this will help deter fraud and educate passengers about the training and behavior expectations of the DOT and the airline industry regarding Service Animals.

Is the Behavior and Training Attestation Form Effective Regarding Training – No ADI, NA feels that the form punishes and discriminates against passengers with legitimate Service Dogs. Passengers with legitimate Service Dogs a training organization accredited by a nationally recognized governing body for service dogs will already have undergone extensive training with their Service Dogs. The dogs’ behavior will be evident in the air travel environment.

The form provides no additional deterrence to passengers traveling with fraudulent Service Dogs than would a simple check off box in the reservation process stating “I certify my dog is a trained service dog and will behave appropriately”.

Ways to Reduce the Burden of the DOT Behavior and Training Form On Passengers with Disabilities Instead of this form, include one box during the reservation process that says, “I certify my dog is a trained service dog and will behave appropriately” for passengers to check off.

7

Should Airlines Be Allowed to Require the Form Each Time a Service Animal User Travels – No ADI NA opposes the requirement of the Behavior and Training Form. Should the DOT require the form, ADI, NA recommends using a universal form annually for a twelve-month period starting on the date of the passenger’s first use for the specific service dog.

Should the DOT follow ADI, NA’s recommendation to include a training and behavior check off box in the reservation form, this box could easily be used for each time the service animal user travels with minimum inconvenience to the passenger.

Preferable Medium Should DOT require this form, ADI, NA recommends all media being accepted by the airlines to fully accommodate disabled passengers traveling with Service Animals. Currently, all passengers may use both paper and digital boarding passes incorporating their smart phones. Similarly, disabled passengers traveling with service animals should have access to the full array of options to produce this form.

ADI, NA emphasizes that including a single check off box in the reservation process would eliminate this dilemma while retaining the same level of effectiveness regarding attestation to the service animal’s behavior and training.

Privacy Concerns ADI, NA takes the position that privacy is a significant concern for disabled passengers traveling with Service Dogs. HIPPA and other regulations protect individuals’ health and medical privacy. This is especially important with individuals who experience a stigma associated with their disability, such as those with psychiatric disabilities, which can easily be exacerbated or triggered by an invasion of privacy, and the extra burden of complying with these forms. Furthermore, disabled individuals may have concerns related to employment, health coverage and benefits and other legal matters that can easily be comprised by an invasion of privacy created by a data base of forms stating they have a disability and other health-related information.

Systems are vulnerable to hacking. Presenting paper and even digital forms in the public environment of the airline ticket or gate counter further invades disabled passengers’ privacy. It stigmatizes them and segregates them in a public setting. This is another reason to use ADI, NA’s suggestion of a single check box regarding behavior and training on the reservation form.

Is This Form Helpful to Airlines in Determining Whether an Animal Has Been Adequately and Properly Training – No This form is not any more helpful than a single check box. Because the single check box is equally helpful and less intrusive, invasive, inconvenient and public, ADI, NA strongly recommends the use of the reservation from single check box for behavior and training.

8

Does the Form Adequately Educate Passengers On How a Service Animal Is Expected to Behave and Seriousness of Fraud – Yes, However, A Single Check Off Box Would Do the Same ADI, NA recommends the use of a single check off box regarding training and behavior in the reservation form. Additional details can be included in the explanation of the box or as a footnote to educate passengers on how a Service Animals is expected to behave. Properly leashing or harnessing a service dog already is part of the national and international standards of Assistance Dogs International and other national and international service dog governing organizations. Allowing disabled passengers traveling with service dogs trained by such organizations to use their own identification to attest to their service dogs’ behavior and training automatically ensures that the passenger will have their dog properly leashed or harnessed.

The other aspects of the form: treating a misbehaving animal as a pet, responsibility for damages caused by the animal and committing fraud through misrepresentation are redundant to existing laws and already known by individuals using service dogs provided by organization accredited by national and international service dog governing organizations.

Should DOT Allow Airlines to Require Only ESA Users to Complete Behavior and Training Attestation Form in The Event DOT Continues to Require Airlines to Transport ESAs – N/A ADI, NA strongly holds the position that the behavioral issues arising from ESAs’ lack of training makes them unable to successfully travel as service animals. Therefore, related forms will only encourage fraud by passengers wishing to travel with ESAs. These passengers already are aware that their animals are not trained, yet, currently submit them to the stress and potential harm to others occurring in air travel. A form does not fix a broken situation. When the situation is fixed, the form is no longer needed.

Content and Layout of Form – N/A ADI, NA feels the purpose of this form can be accomplished by eliminating the form and including a single check off box in the reservation process. Additional information can be included as an explanation or footnote to the check off box.

DOT Service Animal Health Form ADI, NA opposes requiring a Service Animal Health Form. The DOT does not currently require such a form for service dogs, who are trained and required to have health maintenance by the organizations who work with clients in the service dog partnership process.

Additionally, requiring a separate health form imposes an undue physical and financial burden for a person with a disability. Furthermore, having to remit a form online assumes access to technology.

ADI, NA also is concerned that the storage of this information could lead to a registry and is a privacy violation.

9

Is One Year Too Long or Too Short for Vaccination Form to Be Valid – Too Short Some rabies vaccines are for three years. Statistically, more dogs are vaccinated for rabies with a three-year vaccine and requirements vary in each state.

The Journal of the American Veterinary Medical Association wrote,

“Vaccines used in state and local rabies control programs should have at least a 3-year duration of immunity. This constitutes the most effective method of increasing the proportion of immunized dogs and cats in any population.”

JAVMA, Vol. 248, p. 107, No. 5, March 1, 2016

Therefore, a one-year period is too short for the vaccination attestation to be valid.

ADI, NA feels a check box in the reservation process attesting that the service animal is current on its rabies vaccination is preferable. Using a check box does away with the issue of the duration of a form – 1 years vs. 3 years – because the passenger is attesting that the service animal is current on its rabies vaccination at the time the passenger makes the reservation.

Form as Evidence Animal Has Received Rabies Vaccine - NA

Form As Evidence - Aggression – Ineffective ADA, NA greatly respects veterinarians and the AVMA. ADI, NA and the AVMA agree that veterinarians can only attest to the behavior they observe in dogs during the dogs’ visits to veterinary offices. Any other knowledge could only be anecdotal from the dog’s owner and by its definition would not be knowledge at all.

The form states, “To my knowledge this animal described above has not exhibited aggressive behavior or caused serious injury to other persons or animals.”

It is our understanding that the AVMA does not intend this form to attest to the dogs’ behavior outside of its encounter with the treating veterinarian. Therefore, this form is useless in attesting to the dogs’ behavior outside of the observation of the veterinarian, which is the majority of the time.

Should the DOT Permit Airlines, As A Condition of Travel, To Require The Service Animal Health Form – No The form is ineffective regarding behavior, specifically aggression or lack thereof, because the form only covers the veterinarian’s observation of the service animal. An annual veterinarian visit is insufficient to attest to a dog’s overall behavior, including public behavior. Veterinary visits include considerable time with veterinary staff other than the veterinarian, thereby further diminishing the length of time the veterinarian observes the animal.

Instead, ADI, NA recommends a check box on the reservations process attesting that the service animal is current on its rabies vaccine. After the check box, the airlines can have a section for

10 the passenger to fill in the veterinarian’s name, the rabies certification number and the expiration date of the vaccination.

Would the Form Be Effective in Ensuring That the Traveling Public Would Not Contract Rabies from Service Animals Should They Be Bitten – N/A The check box, which ADI, NA recommends instead of a form, will be effective in ensuring the traveling public will not contract rabies from service animals should they be bitten. After the check box, the airlines can have a section for the passenger to fill in the veterinarian’s name, the rabies certificate number and the expiration date of the vaccine.

Health Form – Veterinarian’s Description of Animal, Photo ID – N/A The identification provided by the training organization typically includes a photo ID. As many dogs are “black labs” or “golden retrievers” or “brown ”, such descriptions do not provide helpful information deterring fraud, e.g. substituting a fraudulent dog for the legitimate service dog. As the training organizations already provide a photo ID, requiring an additional one is unnecessary.

Health Form - Content and Layout of Form – N/A

Service Animal Relief Attestation Form – No, Disagree with DOT ADI, NA approves of including this information in the reservation process. Instead of a form, we suggest a simple check off box in the reservation form instead of a separate form.

Should DOT require this form, ADI, NA suggests that the DOT merge this document with the DOT Air Transportation Service Animal Behavior and Training Attestation Form. Combining the documents would eliminate one extra document for the disabled traveler to prepare.

Is The Service Animal Relief Attestation Form Adequate Proof To Verify That A Passenger’s Animal Will Not Relieve Itself In A Way That Does Not Create A Health Or Sanitation Issue - No ADI, NA holds that a form itself is never proof. It is up to the handler to know her or his service animal's ability to refrain from relieving itself for extended periods of time. Relieving shortly before departure is one way to help reduce the possibility of the dog becoming desperate during the flight. The idea of the handler being prepared "just in case" makes sense too. They can do this by carrying a wee-wee pad or doggie diaper, which can be "utilized" in a lavatory onboard the aircraft.

Relief Attestation Form Content And Layout – N/A

DOT Proposal To Prohibit Airlines From Requiring Passengers To Provide The Proposed DOT Health, Behavior and Training and Relief Forms Prior to Travel Date – Agree As stated above, these forms do not provide information helpful to their intent and purpose. Further, as described above, there are alternative methods to obtain this information that do not unduly burden the disabled traveler.

11

Allowing Airlines to Request The Forms, So Long As It Is Clear That Passengers Are Not Obligated to Remit The Forms In Advance Of Their Travel Time – No, Disagree with DOT ADI, NA disagrees with the airlines requiring passengers produce these forms. ADI, NA supports a check box about training and behavior in the reservation process. ADI, NA supports a check box on relief attestation for flights of eight hours or longer in the reservation process.

Is Using Standardized U.S. DOT Forms the Best Way for Airlines to Collect Data From Passengers Traveling With a Service Dog – NO Check boxes regarding behavior, training, health and relief in the reservation process will provide the same level of information as forms.

Checking In One Hour Before General Public Check-In Time – No ADI, NA strongly opposes requiring disabled passengers traveling with service dogs to check in an hour early or being required to go through a process that is different from other passengers. This discriminates against disabled passengers traveling with service dogs.

It also imposes many hardships including the service animals having no access to relief areas for an extra hour prior to flight time.

12