HUD Also Tightening Rules for Emotional Support Animals

sign reads "no pets allowed. service dogs welcome."

The DoT is not the only government agency that is tightening its rules around service and emotional support animals. On January 28, HUD, the Department of Housing and Urban Development, released a notice of its updated rules.

A quick review:

  • The ADA, the Americans with Disabilities Act, allows people who use service dogs to take their service dogs with them to most public places.
  • Air travel is not covered by the ADA. The Air Carrier Access Act (ACAA) covers air travel. The Department of Transportation (DoT) announced proposed changes to the rules around travel with service and emotional support animals. Public comments will be accepted until mid-March.
  • HUD governs housing laws. The new rules have been announced without a public comment period.
  • The ADA public access laws apply only to service dogs (and some miniature horses); a person who has gotten an accommodation for an assistance animal that is not a service dog does not have the right to take that animal to public places that are not open to pets (for example, restaurants, stores, etc.).

HUD’s goal is to help housing providers understand their rights and obligations — and to help housing providers determine whether a request for an accommodation is legitimate.

Both the HUD and the DoT are reacting to dramatic increases in the number of requests for accommodation of emotional support dogs, including requests to allow a huge variety of animals, not always animals that are commonly owned as pets. They are also getting large numbers of requests with no or minimal documentation, including letters provided by online providers.

HUD’s new rules:

  • Adopt the ADA definition of a service dog
  • Treat service dogs and other assistance animals differently
  • Require that individuals ask for an accommodation for an assistance animal
  • Require that individuals provide “information that reasonably supports that the person seeking the accommodation has a disability” — and make the truth and accuracy of this information a requirement of the lease (that is, if the person is later found to have lied about having a disability, the housing provider could evict them)
  • Require that individuals provide “information which reasonably supports that the animal does work, performs tasks, provides assistance, and/or provides therapeutic emotional support with respect to the individual’s disability” with a similar provision about the accuracy of the information

Finally, with rare exceptions, housing providers do not have to accommodate animals that are not commonly kept in households as pets.

The document includes guidelines on what constitutes a “reasonable” accommodation and on how to document a need for an assistance animal that is not a service dog.

 

 

Daniel Was Robbed

A gorgeous golden retriever runs in the show ringI speak for Cali and for golden retriever fans everywhere when I echo the shouts on Twitter: Daniel was robbed!

Daniel is, of course, a golden retriever. Not just any golden retriever. He won Best of Breed and then won the Sporting Group at this year’s Westminster Kennel Club Dog Show. He lost Best in Show to a poodle.

Some of my best friends (and Cali’s) are poodles, but really. That haircut. And did the poodle hug her handler when they won? Or even smile? Did the poodle carry her own ribbon?

Of course not. That’s all so golden-ey.

According to the Washington Post, Daniel’s not bitter. When he got home, he did what goldens everywhere do to relax: He dug a hole in the back yard and lay down in the mud. Cali’s kind of guy for sure.

We’ll be rooting for you next year, Daniel.

Your Dog May Be a Math Genius

Jana, a golden retriever, wears a graduation mortorboardAnyone who has ever out two treats in her pocket and then given her dog only one knows that dogs can count.

Well, it’s more nuanced than that.

Despite many hoaxes and dubious claims, dogs can’t actually count, at least not without extensive training — but dogs are aware of quantities and relative sizes, without any training at all. And, it turns out, they use the same part of their brains that humans do to assess the approximate number of items in an array or group of items.

About those treats — they definitely know when they are being shorted, or the other dog is getting a bigger piece. And they always know when there is (or recently was) a treat in your pocket. They have excellent noses, you know.

Researchers at Emory University (including my favorite dog researcher, Dr. Gregory Berns) put their well-trained dogs back into the MRI and showed them various groupings of black dots on gray backgrounds. This study doesn’t sound like it was as much fun for the dogs as the ones where they got ordinary treats and good treats so the researchers could see how the pleasure centers in their brains lit up … but I bet the dogs were paid well in treats after all the dots.

The published paper talks a lot about the different parts of the brain, but the upshot is that humans and dogs (and lots of other mammals, apparently) react differently when seeing a small quantity of something (fewer than 4) vs. a larger quantity. This useful skill, called numerosity, benefits both predator and prey animals in their search for food or attempts to avoid becoming food.

The dogs in the study had no math training prior to their MRI experience. The advanced mathematical skills that (some) humans possess use the same area of the brain. I wonder how far the above-average dog could get in math with the right teacher.

 

Doggy generalists and doggy specialists (part two)

Cali eyes a bowl of ice cream
Is that for me?

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A couple of weeks ago, I wrote about dogs learning to generalize — to apply a cue in different environments. Dogs can also learn to specialize.

What I mean by that is that they can learn that a cue or rule applies only in very specific situations. For example, I have a TV-watching sofa in the basement that is dog-friendly. I have a living room sofa that is not dog-friendly. The dogs know that they are allowed on the downstairs sofa but not the living-room sofa. (Though, when’s she’s feeling grumpy, Cali has been known to sneak onto the living room sofa, quickly jumping off when I approach and faking nonchalance as she heads to the bedroom …)

Even more specific — the dogs know that they are allowed on the bed only when a particular blanket, the “dog-proof cover,” is on the bed. When that cover is being laundered, Cali will poke her head into the bedroom, scowl (yes, she scowls), and stalk off.

Koala knows to check with her mom about getting on beds and furniture in new places when they travel; she recognizes when a “dog-proof cover” has been deployed and it’s safe to jump on. She’s also much better than Cali about following the rules.

Wylie, Deni’s German Shepherd guide dog several years ago, learned an interesting lesson: Puppy Wylie was chasing wild turkeys in the front yard of Deni’s Montana home when the turkeys played a little prank on him. They led him on a wild chase … right into a wasps’ nest. Wylie never chased turkeys again. Unfortunately, he failed to generalize the “don’t chase wildlife” rule and continued chasing deer until he had some firm training.

Dogs generalize and specialize about all kinds of things. They learn which things are their toys and which things they are not allowed to chew on — even when they share a home with small children whose toys look a lot like dog toys. They learn what they are and are not allowed to eat. They might know to bark at some noises and not at others or that they can get on the bed only when invited.

Dogs’ ability to specialize and generalize can get humans into trouble.

What if, for example, you have been strict about not feeding the dog from the table, teaching your dog to lie quietly while you eat. But … your spouse sneaks her treats on the sly.

You’ve begun to notice that, although the dog behaves while you are eating alone, if your spouse is there, she begs. Even worse, whenever anyone else is over, she hovers hopefully, testing each new person to see whether he’s a stickler for your rules — or is a softie, like your partner.

This points to a universal human failing: Inconsistency.

The dog has learned not to beg from you at the table. She has not generalized the rule to “no begging at the table.”

Instead, she has taken what you intended as a general rule and figured out that not all the humans know or care about this rule. Indeed, she has exploited the begging loophole (along with her long blond eyelashes and her talent at manipulating your humans…) to establish two different rules: She has determined that the specific rule is “do not beg from mom” and the general rule about begging is “it depends.”

Then, she has decided that she needs to figure out which rule each new human uses. Some will be sticklers; some will be softies.

Unfortunately, the more people in a household, the more likely it is that they will enforce rules inconsistently. Even in a household of one, alas, it is possible (likely!) to enforce rules inconsistently, leading the dog to learn rules that are quite different from what was intended.

 

Flying Dogs, Redux — Comment Now on Proposed Rule Change

Department of Transportation logoWell, it’s the topic that never dies. In a post just over a year ago, I shared the “final” rules that the Department of Transportation issued on traveling service and emotional support animals. My skepticism of the “final” part was well-placed. The DoT is proposing a new set of “final” rules.

These changes would bring the rules for air travel more in line with ADA laws governing public access, including recognizing psychiatric service animals.

The new rule would define a service animal as “a dog that is individually trained to do work or perform tasks for the benefit of a person with a disability,” echoing language from the ADA.

The most dramatic changes are limiting travel access to service animals — specifically, service dogs — and no longer requiring airlines to accept emotional support animals in the cabin or treat them differently from pets.

The proposed rules would also allow the DoT to create forms “attesting to a service animal’s good behavior, certifying the service animal’s good health, and if taking a long flight attesting that the service animal has the ability to either not relieve itself, or can relieve itself in a sanitary manner” — and allow airlines to require that passengers traveling with service animals complete these forms.

Other provisions include allowing airlines to:

  • Require that passengers traveling with service animals check in earlier than other passengers
  • Limit the number of service animals to two per passenger
  • Require that the service dog(s) fit within the passenger’s foot space in the cabin
  • Deny travel to animals showing aggression

Notably, airlines could not, as Delta has tried to do, deny access to dogs based on their breed.

The 60-day public comment period opened on January 22, 2020. To comment, go to the docket page, where you can also read the full proposal and other comments.

Doggy generalists and doggy specialists (part one)

Cali, a golden retriever, sits in the kitchen doorway

I’ve recently heard not one but two experienced trainers, trainers I admire greatly, say that dogs don’t generalize.

What?!

The most recent incident was in a training class. The trainer was talking about practicing at home and said that dogs don’t generalize as a way to explain why the dog’s reaction to a cue or a piece of training equipment might be different at home than at the training center.

Generalization, in a dog-training context, means that the dog can recognize a cue in different environments. Some examples:

  • Your dog has been to your  neighborhood dog park a bazillion times. She’s been to the dog park near your parents’ house a half-bazillion times. When you take a road trip and stop at a dog park you find near your hotel, she immediately recognizes it as a dog park and runs off happily to play.
  • Your dog has a toy box. Your sister’s dog has a toy box. Your parents’ dog has a toy box. Your dog happily helps herself to toys from the toy box at each home. You visit a dog-owning friend for the first time. Your dog homes in on the toy box, grabs a toy, and the dogs start playing.
  • Your dog knows to sit quietly and wait while you prepare her dinner, waiting until you say, “OK” before gobbling her food. She does this whether you’re at home, in a hotel, at your mom’s, or anywhere else.
  • You’ve taught your dog not to jump on visitors. A new visitor comes into the house. Your dog has never met this person before, yet she knows not to jump on him.

I could go on, but I am guessing that you get the picture.

Of course dogs generalize. They could not possibly learn otherwise. No one could. There is simply no way to create and practice every single scenario where the dog will be asked to sit or lie down or wait for food or not jump —  or do / not do anything you might imagine.

Dogs learn to generalize as they learn to learn — with repeated practice. With a new puppy (or newly adopted dog of any age), you start teaching the dog house rules. You also (one hopes) teach basic manners, things like not jumping on people, not mouthing people, not barking every time the next-door neighbor walks past the window. Then, other members of your family ask the dog for the same things. And visitors do. You ask for them when you are in the kitchen, the living room, the basement, and the back yard. And on a walk or a road trip.

Your dog learns, after experiencing this phenomenon a few times, that the cue applies everywhere. The dog then generalizes that knowledge to other cues. Verbal cues: “Sit,” or “Quiet.” Visual cues: the toy box or dog park. Routine cues: you putting on the shoes you always wear for walks or closing down your laptop at 5 pm. These cues, and similar cues, take on meaning that applies even if you are not in the same room or you’re visiting someone else’s house or the toy box looks and smells different.

By the time you’ve taught your dog a few cues, she’s figured out generalization.

You can also teach your dog to specialize, which I will talk about in next week’s post.

 

The saddest sounds

10-week old Cali, a golden retriever, lies on a brown dog bed
Don’t leave me …

A recent Bark column muses on humans’ susceptibility to manipulation by dogs. Specifically, by the sounds they make in sadness. Sadness that occurs only because we humans are not meeting their expectations.

Boy do I know how that works.

When Cali was a tiny pup and Jana a beleaguered 8-year-old with a new baby sister, I made a point of taking Jana for a (very short) solo walk each day. This was partly to get Cali used to being alone briefly. The first time we did this, within seconds, the saddest, most mournful howl I have ever heard wafted out through an open window. I was probably a whole 10 feet from Cali but, you know, there was a wall in between.

Cali has deployed this mournful howl a few additional times over the years. (She’s 7 now.) She’s added to her repertoire, too. She has a range of sounds, including sighs, snorts, scowls (ok, those are silent), exasperated exhalations, grumbles and mutters under her breath, and more. And, yes, a whine. It’s a tiny whine, very soft and short. It’s also very, very sad. Heartbreakingly sad. This whine is used only when Cali is outside and wants to come inside, and no one is there to make the door magically open.

This, naturally, happens only when Cali has refused to come inside despite being offered several opportunities, and I have given up(!) and gone upstairs to work. Within oh, about 3 minutes, there’s that tiny whine. I could easily miss it but somehow it penetrates whatever fog of concentration I am in. When I go back downstairs to let her in, Cali is always happy, relieved, and reproachful, all at once.

I’m not the only one to be expertly and repeatedly manipulated by a sad dog.

My doggy cousin, Jaxson, has created a magical combo, a unique whining sound plus guilt-inducing look, that gets him the most coveted seat in the house: Literally in between his mom and dad. The one space on the sofa he’s theoretically (very, very theoretically) not allowed. There’s nothing unique about dog whines, of course. Whole orchestras could be woven out of different dog whine. Jaxson’s whine is unique in that this specific note is deployed only when he’s on the sofa but not between them. That is, only one pair of hands can reach him to pet him and only one person’s attention is focused on him. The unique sound effectively terminates this intolerable condition.

The Bark column mentions research that found that humans with pets are more susceptible to animal distress vocalizations than other people and that “dog whines sounded saddest of all, and sadder than cat meows.” Other research has found huge changes in canine vocalizations as a result of their domestication. Sure. They’ve got our number. They’re pulling out all the stops in their quest for the upper hand … er, paw … in the household.