What’s Missing from the Conversation

Alberta, a now-retierd yellow Labrador guide dog, leads DeniI wrote a post a few weeks ago about proposed new rules for flying with service and support animals. Lucky for me, most Thinking Dog readers are kind and thoughtful individuals.

Deni wasn’t so lucky. That could be because she had more than 2,000x as many readers as I generally do … in just the first 3 days (and no, that’s not a typo).

The comments on her article, and on the proposed rules at the DoT site, reveal much about our society. And why the concept of ESAs has been so badly abused. They follow several general themes:

  • People who hate animals, kids, anyone who writes about animals, and pretty much the whole world. (These are best ignored.)
  • People who think all animals should be banned from airplanes, including guide and service dogs, due to their own (or others’) allergies. (Not gonna happen.)
  • People who say they cannot or will not fly if they cannot bring their ESA.
  • People who use service animals and oppose any sort of behavior or health check or documentation.

What is missing from this conversation, as well as from the laws and proposed new rules, is attention to the animals’ welfare and needs.

Some of the people who can’t or won’t fly without an ESA could well be able to meet the legal threshold for a service dog. Others have generalized and severe anxiety or anxiety specifically about flying, so the presence of an animal is of comfort and helps them cope.

I am sincerely empathetic. At the same time, I think that’s a lot of responsibility to place on an animal, especially one that has not been trained to work under stressful circumstances. Public access is stressful for any animal, but especially one that essentially lives in a familiar home, rarely leaving except, in the case of some dogs and cats, for walks around the neighborhood. Airports and airplanes are about as stressful a situation as I can imagine.

I also worry that someone with severe anxiety would be stretched to the limit taking care of their own needs and would be unable to safely handle an animal, intuit and meet its needs, and keep themselves, the animal, and other passengers safe.

The untrained pets used as ESA are often terrified by the commotion, cramped quarters, noise, smells, and general awfulness of airports and airplanes. And that is exactly the problem: No one is evaluating the animals or training them to get used to public access. People with ESAs do not have the right to take them in public (the ADA gives that privilege only to people with both a disability and a trained service animal) and no training is required, so even if the people wanted to prepare their animals, they cannot legally do so.

Like other pets, most ESAs spend the majority of their time at home. Then, suddenly, they are taken to the most stressful place possible, by a person who is extremely anxious. As a living being with needs and fears, the ESA needs and deserves the protection of its person — a person who at that time is very unlikely to be able to provide that protection.

The law currently allows anyone whose mental-health professional (or internet store) supplies them with a letter attesting to their own need for the animal. Nothing addresses the suitability of the animal or its welfare, and nothing safeguards the public from terrified animals (mostly dogs) behaving like terrified animals: Growling, yowling, snarling, lunging, biting, peeing, etc. It’s a testament to how resilient and generally amazing dogs are that there have not been far more bites.

I am a former service dog trainer and am adamantly opposed to creating barriers to access for people with disabilities. At the same time, I do not think it is possible to protect public safety — including the safety of service dog teams — without limitations, such as a public access test and health requirements.

Public access with a service dog in a no-pets area is a privilege that does not include the right to endanger others or trample their rights. The ADA builds that in; a service animal that is dangerous or behaving inappropriately can legally be excluded even if the person has a disability and the animal is fully trained to mitigate that disability. The current ACAA rules on ESAs do not. And it is not reasonable or realistic to expect TSA officers or airline gate agents to be able to assess which animals are safe and which are not — and to be effective at barring those passengers and their animals.

There are ways to make health checks and public access tests easy, certainly no more complicated than getting a disabled parking placard in most states.

Thousands of dog trainers are capable of administering a CGC test, for example. A public access test could be similar, and it could be conducted by any certified dog trainer in a place the team goes anyhow, like Walmart or the supermarket.

Keeping your dog healthy and being able to show that the dog is vaccinated are minimal standards when taking your dog anywhere, even the dog park.

I don’t see these as huge obstacles or burdens. One comment I saw talked about the nearest Walmart being over an hour’s drive and said having to go to a testing site would be an enormous burden. If that person never, ever goes to that distant Walmart, or anywhere else in public with their service dog, they wouldn’t need to do the test. If they do go there, even rarely, doing a test there once every year or so is not a huge ask.

Airlines could help out by keeping paperwork on file, though, as they keep seating preferences and contact details for mileage club members. Asking people to jump through the same hoops every time they fly is absurd, especially for anyone who flies multiple times a year. Linking the health certificate and other info on the team to a flyer’s frequent flyer profile, with a flag for annual updates, is very easy in our digital age.

Allowing only trained, professionally evaluated animals to fly in the cabins of airplanes, and asking that other animals either remain in carriers that fit under a seat or that their owners make other arrangements is common sense. It respects the rights and safety of people with disabilities who have trained their (mostly) dogs and rely on those dogs’ assistance. It also respects the rights and safety of everyone else.

My comments are, of course, my opinions; reasonable people may well disagree. I think that Deni wrote a solidly researched article that presents a real problem and suggests viable solutions. I encourage you to read it, read the proposed rules, and comment. The 60-day comment period opened Feb. 5 and ends in early April.

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 February 5, 2020. To comment, go to the docket page, where you can also read the full proposal and other comments.

“Final Word” on Flying Service Animals

Your seat-mate on your next flight?

The US Transportation Department (DoT) has issued a “final” statement on service animals in air transportation. I’m a bit skeptical of that finality, but it’s definitely worth taking a look at what is the current last word.

When I last looked at this, airlines were issuing strict new policies, and the DoT was taking public comment on changes it was considering. They received more than 4,500 comments, and have released their final (for now) policy.

Here’s a summary:

  1. Airlines cannot categorically ban specific breeds of dogs. They also cannot categorically refuse to transport all animals that are not dogs, cats, or miniature horses. They can refuse reptiles, ferrets, rodents, and spiders. The “emotional support peacock,” and possibly the pig, however, appear to be cleared for takeoff.
  2. Passengers may travel with a total of three service animals, including one ESA; the DoT will focus enforcement on passengers who’ve been prevented from traveling with up to 3 animals, but will not allow airlines to enforce a strict limit at all.
  3. Airlines may not categorically ban animals over a specific weight, but they are allowed, on a case-by-case basis to refuse to allow an animal in the cabin if it is too large or heavy. That could mean weight- or size-related bans on certain smaller aircraft, but not, as some airlines have tried, across-the-board weight-based bans.
  4. Airlines may ban “service” animals that are younger than 4 months, since  “those animals would not be trained to behave properly in a public setting.” But the DoT does “not anticipate exercising our enforcement resources” in this area.
  5. Airlines may not ban emotional support animals (ESAs) on flights longer than 8 hours. They can however require anyone traveling on longer flights with a service animal to provide documentation that the animal either “will not need to relieve itself on the flight or can do so in a way that does not create a health or sanitation issue on the flight.” There’s no hint as to how someone might document that. They may also require 48 hours’ notice that a passenger has a service animal and they may also require early check-in, in person, in addition to the documentation.
    Note that the document uses “service animal” as a broad term that includes ADA service animals, emotional support animals (ESAs), and psychiatric service animals (PSAs). I believe that this will prove to be an enormous hassle for people traveling with, say, guide dogs or mobility service dogs, on long flights.
  6. Airlines may request documentation from a medical professional from passengers seeking to travel with an ESA or PSA and can request but cannot require that passengers use a specific, airline-created form.
    In addition, they may ask any passenger traveling with a service animal “limited questions” to determine the passenger’s need for the animal, regardless of whether the animal has a tag, vest, or other service dog paraphernalia. What these questions are is not stated.
    Note that the ADA does not apply to air travel, so airline personnel are not limited to the ADA questions (whether it is a service animal and what task it does).
  7. Airlines may not require people with disabilities using task-trained, non-ESA/PSA service animals to produce documentation in advance of travel. However, airlines may request documentation related to “vaccination, training, or behavior” if the airline reasonably believes the documentation would help assess whether the animal poses a “direct threat to the health or safety of others.”
    There is no explanation of what form this documentation might take or how it might help make such a determination, so this point could be very problematic. They do not envision taking enforcement action against airlines asking for this documentation.
  8. Airlines may require passengers traveling with ESAs or PSAs to check in, in person, in the airport lobby and present their documentation — prior to entering the “sterile” area (post-security check). They may also require these passengers to provide 48 hours’ notice that they are traveling with an ESA or PSA and require them to check in up to an hour earlier than other passengers. These requirements do not apply to non ESA/PSA service animals (which are not defined).
  9. Airlines may require that service animals of all types be “contained” (including leashed), and complaints will be evaluated case-by-case. In general, requiring some means of tethering is allowed.
    But … While airlines may make other requirements to ensure safety and to ensure that other passengers have use of their “foot space” — but they also have to  allow the animal to provide emotional support or perform tasks. Translated, that means people may be permitted to remove their ESAs from crates (and we all know that people do so even when it’s not permitted).
  10. Airlines cannot limit the total number of service animals on any flight (including ESAs and PSAs).

That’s a lot. It’s similar to the interim document that has been in force for a little over a year. But it certainly does not address the clear problems that triggered the new document, which included rampant fakes, non-domesticated animals with no training traveling in crowded planes, along with untrained, stressed, and sometimes aggressive dogs, and people with trained service dogs being hassled and worse.

Under the new policy, the documentation that airlines can require for non-ADA service animals is vaguely defined, and what they can ask of service dog users is not defined at all. Airlines still will rely on check-in personnel, who are not animal behavior experts, to evaluate whether an animal poses a risk. They’ll still face pressure to accommodate unsuitable animals. Lots of them. I’m imagining planes full of people with 3 “service” animals apiece, all outside their carriers.

Walking into the lobby of an airport is an unusual activity and would be stressful for an animal not trained for or used to public spaces. Since there are no laws that grant public access to people with ESAs, and no training is required, this describes most ESA.

But that’s just the beginning; an untrained staffer might not notice that an animal is stressed at this early stage. Airline personnel have no expertise or way of evaluating whether an animal will remain calm under stress or whether the person can safely handle the animal during travel. Many handlers wouldn’t notice or be aware of signs of stress. The animal’s stress level is likely to rise as new, weird experiences pile up: TSA check; maybe riding on a tram of some sort; sitting in a crowded gate with loud noises and anxious people; being stuffed under a tiny seat, hemmed in by strangers; more loud noises and weird smells … Under increasing stress, it’s likely that more animals will react quite naturally — and people will get hurt. And when the untrained, stressed-out dog stuffed under the middle seat bites the passenger in the window seat, that poor person is still trapped in a tiny space with no way out.

The DoT’s mission was to protect the safety of all travelers, the rights of people who are legitimate service animal users, and the safety of traveling service and support animals. The new regulations were intended to address a tsunami of fake service and emotional support animals on airplanes, traveling with people ill-prepared to handle them safely. I don’t think that this document comes close to accomplishing any of those goals. In fact, the new policies might invite even more abuse than the old rules.

Time to Weigh In on Flying Dogs (Hurry!)

Koala, a black Labrador, rests. She's wearing her guide harness.
Koala is an excellent traveler.

The peacocks, the pets trying to travel as service or emotional support dogs, the misbehavior — from pooping pigs to biting dogs — and the “service dog” whelping her litter near gate F81 … it’s all too much.

Not only are airlines tightening up their rules on which of our furred, feathered, and scaled friends may board, the Department of Transportation is considering changing sections of the Air Carrier Access Act (ACAA), the law governing air travel with service and emotional support animals.

The root of the problem is that federal laws governing access for assistance animals are vague, different laws allow for different things in different spaces (public businesses, housing, and air travel), and it’s easy to exploit loopholes or deliberate omissions in these laws. The result, as far as air travel is concerned, is a mess.

In a nutshell, the ACAA allows people to travel with service animals or with emotional support animals (ESAs). The ACAA definition of a service animal is different from the more familiar ADA (Americans with Disabilities Act) definition; the ACAA definition of ESA is loose indeed. For one thing, no training is required; for another, passengers are not required to crate or otherwise contain the animals during the flight.

Problems include threats to (and harm to) the safety of other passengers, interference with legitimate service animals working with their partners, and undue stress on the animals themselves, who generally have had no public access training and should not have to endure a strange, noisy, smelly, stressful, cramped, terrifying experience (air travel is all of that and more for me, and I am used to it!).

The DOT is soliciting comments by July 9, 2018 specifically in these areas:

  1. Psychiatric service animals; ADA treats (some) PSAs as any other service animal, while the current ACAA groups them together with ESAs
  2. Whether to maintain the distinction between ESAs and service animals
  3. Whether ESAs should be crated or otherwise confined / restrained throughout the flight; similarly, they are soliciting comments on whether service / ESAs should be required to be leashed or tethered
  4. Whether to limit what species of animals would be permitted to fly as service and/or ESAs; ADA allows only service dogs and a limited number of miniature horses
  5. Whether and how to limit the number of service / ESAs a passenger may travel with; currently neither the ACAA nor the ADA limits the number of animals
  6. Whether to require that passengers with a service or ESA should be required to attest (sign a statement declaring) that the animal has been trained  for public access
  7. Safety concerns regarding travel with “large” (undefined) service animals and suggestions for addressing those concerns
  8. Whether airlines should be allowed to require a veterinary health form or immunization record from any or all service animal users
  9. Issues with airlines denying / allowing passengers to board with ESAs / service animals on foreign airlines’ code-share flights

For more details, read the full notice. Post a comment here. Read others’ comments here.

Post your comment by July 9!

Wrong on So Many Levels …

a poster announces that service dogs are welcomeI was in St. Petersburg when the Tampa Bay Times ran this story about a “service dog” whelping a litter of puppies at the Tampa airport. Columnist Daniel Ruth’s response is spot-on. This is so, so wrong.

The initial article said that the dogs’ owner claimed both dogs (the puppies’ dad was present for the whelping) were service dogs; it also said the puppy-mom was a service dog in training. The initial article says that the owner has mobility issues; Ruth’s column mentions blood pressure. It’s impossible to know which is accurate or whether the owner meets the ADA definition of a person with a disability. It’s also impossible to tell whether either or both dogs do anything to mitigate the disability. While the reporting could be more clear, part of the problem is that the various laws covering public access and air travel with service dogs are so vague and poorly written that they are a nightmare for gatekeepers — and an engraved invitation to fakers. (I’m not saying this person was faking; I am saying it is nearly impossible to know.)

The second problem is that it’s legal in some cases for people to use two service dogs and request public access with both simultaneously. I know that people might have multiple disabilities that a dog or dogs can help with. And if you’re an owner-trainer and want to train a dozen service dogs for yourself, I don’t think any law should stop you. But I also advocate for some common sense in access laws.

I’ve worked with dozens and dozens of service dogs. Even the best dogs get spooked in airports or on planes, and I know that it’s hard enough to find and train one dog for the really difficult, demanding job of working while traveling, through an airport, and on an airplane. Expecting someone to be able to safely handle more than one dog in these circumstances, while dealing with the many hassles of travel — that’s just not reasonable. It’s not fair to other travelers or to airline staff. No one can predict what will happen. I’ve seen “service” dogs react aggressively to working dogs, kids come out of nowhere to grab the dogs in a hug, people interfering with dogs by doing everything from reaching to pet to trying with gestures and noises to distract the dog to actually enticing working dogs with food.

Add to that the exploding number of emotional support animals traveling these days — a concept that many people, including Ruth, in his column, have trouble separating from service dogs — and I’m surprised that any dog can navigate air travel without losing her cool. Expecting a person, any person, to keep tabs on multiple service dogs with all of that going on, and keep everything under control so that the traveler, dogs, and everyone else is safe? Not realistic.

Finally, the most egregious part of this story: Who boards a plane with a dog who’s that pregnant? It’s not that hard to know when a dog is due to whelp. Gestation is about 60 days. If your dog has been bred, don’t travel after about 6-7 weeks. And that doesn’t even address the bigger issue: Any professional service or guide dog trainer will tell you that a working service dog should be spayed or neutered. Regardless, a pregnant female shouldn’t be working that close to her due date. And if she is a service dog in training, as some accounts said, she shouldn’t have been allowed to fly anyhow; no law gives access to service dogs in training. (In a probably vain attempt to forestall criticism, I will state that I think that trainers should be able to fly with dogs-in-training, but that is a whole separate issue.)

A service dog partnership is not a one-way street. The dog helps the person in a way that only a dog can. The dog also provides companionship and love. In return, the person owes the dog care and respect. I don’t doubt that the owner of these dogs loves them and appreciates their service. But she did not fill her obligations as their guardian and steward and advocate, nor did she show respect for the dog when she let a working dog become pregnant and then attempted to fly with that dog so close to her due date. The person’s needs do not always come first, and in this case, the owner was selfish and irresponsible.

As a person who cares deeply about the human-canine connection while also deeply respecting the work dogs do for us, I become angry when I see or hear about any dog owner who treats her dogs that badly, whether they are service dogs or pets. (I’m not alone; the Times apparently heard from lots of others who were outraged.) While travelers who saw the puppy birth might have thought it wonderful, miraculous, cute (or gross), that this poor dog had to whelp her puppies in such awful, public conditions is outrageous.

Too Much Nurturing?

Jana, a white golden retriever, wears a mortarboardReading about this study will make you want to go back to college.  A team of undergrad researchers had the best job ever: Watching hundreds of hours of puppy videos.

They were looking at the differences in how moms at The Seeing Eye, a guide dog school in New Jersey, treated their pups. Some were very attentive, constantly licking and cuddling their newborn pups. Others spent as much time as they could out of the whelping box, away from the babies. Some lay down to nurse, making it easy for the pups to gorge themselves. Others stood, perhaps longingly eyeing the happy hour menu just out of reach. The researchers not only studied the moms’ behavior, they also measured their levels of cortisol, a hormone that indicates stress. Moms with higher anxiety tended to spend more time with their pups and coddle them more.

Guide dog puppies are set up to succeed. They have great genetics and prenatal health care, as well as top-notch vet care throughout their lives. They get early enrichment and socialization, lots of training. Even so, many don’t make it. A dog who is nervous or fearful makes a poor guide, as does one who can’t think independently and solve problems. Puppies who learn faster, solve puzzles faster, or figure out how to contend with obstacles naturally make better guide dogs. So do puppies who are confident and unafraid of new or potentially scary objects or situations. Temperament tests for puppies abound, but it’s still hard to reliably predict adult temperament or success.

It might seem that pups with attentive moms would be more confident and therefore more likely to succeed. But that’s not what the research indicated. The pups who had to work a little harder to eat and those who were less coddled by their moms turned out to be more independent and better problem solvers — scrappy, tough little dogs who had higher success rates in guide dog school. The coddled pups showed higher anxiety and less problem-solving ability. Even these pups are far ahead of the average pet dog in terms of temperament, ability to cope with the everyday stresses of life, and general health, though. But helicopter moms seemed to put their pups at a disadvantage.

It’s hard to determine just how much of the pups’ success or failure is linked to maternal behavior and how much is genetic, so more study is needed. But the attention to maternal behavior could help shape early training and enrichment. It could also point to ways that we could more successfully help our older puppies and adult dogs cope with anxiety (less coddling?).

Anyhow, doing more research is so appealing. Sign me up to watch those puppy cams!

The early study on maternal behavior is available online: Characterizing Early Maternal Style in a Population of Guide Dogs.

The abstract of the later study is available here: Effects of maternal investment, temperament, and cognition on guide dog success.

A Dog Can Help You With That …

Whatever you need help with, chances are, a dog can help out. Need help finding your way around? Easy-peasy. Need a guide who also lets you know about important sounds? Dog’s got that handled too.

Funny thing is, not too many humans believe that dogs can do all that (and more). Fortunately for some people, Guiding Eyes is an organization that takes chances on people — and dogs.

As someone who’s sure that we haven’t come close to tapping dogs’ full potential, I see this as a sign that Guiding Eyes (or GEB) really “gets” dogs in a way that few people, even dog professionals, do.  This understanding leads the organization and its trainers to willingly take on challenges that few people would even think possible: Tasks that require a belief in dogs’ ability to be adaptable and to become creative problem solvers, for example. GEB dogs do things that it’s really not possible to teach them without a shared understanding and buy-in to shared goals, so the trainers have to know that dogs are capable of higher-level thinking, problem solving, and working toward goals.

What do I mean? GEB places dogs with a tremendous variety of clients, including individuals who have both visual impairments and another disability, such as a mobility or hearing impairment. The clients whose dogs alert to sounds as well as guiding range from people who are legally blind and hard of hearing to individuals who are both blind and deaf. I could be wrong about this, but I believe that GEB is the only U.S. guide dog school that is willing to provide these clients with a guide dog. In any case, it was the first organization to do so.

As registration opened for the Guiding Eyes continuing education weekend, a number of these grads registered. Planning committee member, grad, and GEB consumer outreach and graduate support manager Becky Barnes Davidson waved a magic wand and somehow found funding to bring a cadre of interpreters to the weekend, ensuring that all of the grads could participate fully in the events.

Deborah and Gypsy walk togetherI had the opportunity to chat with one of these grads, Deborah Groeber. She got her first Guiding Eyes dog in 1987. GEB didn’t yet have its “Special Needs” training program, which got off the ground in 1990, but, Deborah said, it was the only guide dog school willing to try training a guide for her.

Having guide dogs has, of course, made a tremendous difference for Deborah, especially in her frequent travels. She describes traveling with her dogs (current guide Gypsy is her fifth) as “phenomenally different” from traveling with a cane.

“I think Gypsy is a great match for me because she loves going from the suburbs into the city every day, loves taking trains, buses, escalators, stairs, revolving doors and working obstacles and construction sites. She is bright, confident and self-motivated, but she also loves praise and food rewards,” Deborah said.

Deborah is about to participate in another unique Guiding Eyes program. Gypsy is nearing retirement, and Deborah’s next guide will be a member of GEB’s new program, Running Guides.

Running Guides perform the usual guide dog work as well as guiding their partners while running. The first Running Guide team graduated in 2015. And Deborah’s dog will, as Gypsy has, learn to alert her to sounds, such as smoke alarms, phones, and doorbells. Deborah knows how to teach her additional alerts as needed. Sometimes Gypsy figures it out on her own, too.

Once, not long ago, Gypsy alerted her to a carbon monoxide alarm when Deborah’s husband was traveling for work. Gypsy is not allowed in the basement, Deborah explained, but she kept alerting to the basement door, because she heard the unexpected sound of the alarm. She’d not been trained to respond to that sound, but somehow understood that it was an urgent problem. Deborah got both the CO and smoke alarms, Gypsy told her which one was making noise, and she was able to respond and resolve the problem.

That story underscores the connection and communication that develop between members of a guide team. Many of us plain old pet-dog owners, who have the good fortune to be able to see our dogs’ body language and hear their vocalizations, are nonetheless unable to figure out what they are telling us. And I bet most of our dogs would react to an alarm and try really hard to get us to do something about it. That we’d all die of carbon monoxide poisoning anyhow would not be the dogs’ fault…

As someone who has tremendous faith in dogs’ abilities to figure things out, communicate, get what they need, figure out what their humans need, and so much more, I am not amazed that a single dog can perform both guide and hearing work, with a side gig as a personal fitness trainer. I am impressed that enough people at Guiding Eyes believed in dogs back in 1987 to give combined guiding and hearing dogs a try, and that the organization is continually coming up with new ways to stretch and grow the partnerships between their amazing dogs and clients.