“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.

How do you choose a boarding facility?

A white golden retriever, Jana, reclines on a sofa
Leave your dog in the lap of luxury when you travel

You’re going on a trip. Hooray!
Your dog isn’t. Now what?

First, consider your options.

You could have a sitter stay at your house. Advantages include less disruption of the dog’s routine — this was my go-to when Jana was elderly and anxious — and it’s convenient. No drop-off or pick-up. But you do need to prepare the house, maybe make up a guest bed, and be prepared for a relative stranger to live in your space. You have to really trust the person.

You could leave the dog at a sitter’s home. This is easy, and often less expensive than a boarding kennel. The dog is likely to get lots of attention (if you’ve chosen your sitter well). You also need to really trust the person.

Some sitters take only one or two dogs at a time, while others board multiple families’ dogs. Find out how many other dogs will be there, and decide whether that will work for your dog. Clarify what exercise and play opportunities the dog will have. Ask about sleeping arrangements, and ask how much time the dog(s) are left home without human supervision.

If these options don’t work for you, you might look at boarding kennels. These range from a few cages at the back of a vet hospital to luxurious pet ranches. The price and the amenities do not always correlate, so visit any place you are considering and ask a lot of questions. Basic, essential questions include:

  • How many dogs are boarded at a time, and how many staffers are on each shift?
  • Is someone on site overnight? If not, what time do they leave? What time do they come in? Does someone come in in the late evening to let the dogs out? Or do the dogs have access to a potty area? Your goal is to find out how many hours the dogs are in their kennels or crates. In some places, it’s 12+ hours!
  • Where do the dogs sleep?
  • What exercise and play opportunities are included? What costs extra?
  • How many hours a day is the dog kenneled / crated?
  • Where do the dogs sleep? Do they have blankets / beds or are they in bare runs?
  • Are they fed their own food or does the kennel feed everyone an in-house food (should be dog’s own diet)?
  • What vet do they call if there’s a problem (should be your own vet)?
  • How are dogs grouped for play? How are they supervised?
  • How do they handle special diets / medication and avoid mistakes?
  • Do they send you updates or photos?

Look at the kennels and play areas. Do they look secure? Kennels should have solid walls and, ideally, be separated. Long rows of mesh fences are a bad sign. Being kenneled right next to other dogs, with no way to “den” or get away from the other dogs’ gaze is very stressful for most dogs.

A kennel I used a long time ago had several small garden sheds set up for the dogs’ sleeping accommodations. Each had its own dog door to its own potty yard, available all night. The dogs were “tucked in” at night by a staffer, who stayed on site overnight. That’s a great setup.

Another kennel I used had regular wire-fenced kennels (not for my dog!) and a few separate rooms. With actual walls. Our dogs could share a room (with no non-family dogs), and have their own bedding. They were away from the chaos and stress of the kennel area. It was still stressful and not ideal, but it was an acceptable solution.

Finding the right place requires doing your homework. You might visit several kennels or interview a half-dozen sitters before choosing. Get recommendations from picky friends if you can. Once you’ve been to a kennel or sitter, pay close attention to your dog’s reaction. Is she dragging you out of there or happily interacting with the staffers while you settle your bill?

Oh, and have a great trip!

 

Distracted Driving

SleepyPod's large and small crash test dogs
SleepyPod’s hard-working crash test dogs

How do you keep your dog safe in the car?

On long trips (anything involving a freeway), I use a dog seatbelt. Koala likes to ride on the floor, in the footspace behind the front passenger seat.

Since I have a run-of-the-mill dog seatbelt restraint, neither of these options is particularly good. Better than letting the dog sit in the front seat or, worse, on my lap. And way better than letting her ride, loose, in the back of a pickup — all things I see often.

The issues are both her safety and mine. A dog can be distracting; I’ve driven dogs who pace on the back seat. And if I have to stop suddenly, the dog can fly off the seat and get hurt. In an accident, the dog could fly through the windshield or crash into the driver or a passenger. Or escape and get lost or hurt.

Hence the seatbelts.

AAA recommends restraining pets inside the car, in the back seat, using either a seatbelt attachment (like mine) or a crate, which is itself strapped in. These take care of the distraction issue and would provide some protection from a hard stop or mild fender bender.

The advice to let dogs ride only in the back seat is significant. It’s not only about distraction. If you are in an accident that causes the airbags to go off, your dog is very likely to be severely injured or killed by the airbag. That is why small children cannot ride in the front.

A small dog dangles from a car seatback, held by a Rocketeer harness
Rocketeer for small dogs

There’s a more secure option, one that also dramatically improves the pet’s chances of surviving an accident safely. There’s an organization called the Center for Pet Safety that tests (among other things) pet seatbelts and rates their performance.

They paid for extensive crash testing, and came up with a (very) few certified harnesses: three. These are the SleepyPod Clickit Sport and Terrain and the ZuGoPet Rocketeer.

The Rocketeer is for dogs up to 25 pounds only and is sort of like a baby carrier that you wear on the front. Only the car seat back wears it. A little weird.

You can actually watch video of the crash tests on the CPS website.

They are pricey: The Rocketeer starts at about $100, and the SleepyPods, for dogs 18 to 90 pounds, start at $70.

Duke, the new-and-improved crash-test dog, works hard to make SleepyPods safe (if you believe the video on the company website). The video is scary. Cali might be getting a brand-new, Duke-approved harness before our next road trip. Frankly, I’d feel safer if Duke came along for the ride as well!

 

A Great Idea!

A screen shows the Tesla Dog MOde message, My owner will be back soon.

If only Cali could afford a Tesla …

Several weeks ago, Tesla rolled out a software update that introduces “Dog Mode.”

This is a feature that allows car-and-dog owners to set a cabin temperature for their dogs’ comfort while they go off and … do whatever it is people do while leaving their dogs in the car. The car’s heating or cooling system will maintain the appropriate temperature automatically. Here’s the cool part: The Tesla’s screen shows a message meant to reassure worried passers-by that the dogs are OK. It reads “My owner will be back soon” and displays the interior temperature in large numerals.

The main hitch I see is that the screen, which is usually used for the car to communicate with the driver, is positioned between the front seats. People passing by and noticing dogs in a closed car in extreme heat (or cold) may not peek in at the right angle to see the screen. They might still panic, break a window, call the cops, leave a nasty note for the owners, alert the security at the nearest store, etc.

However, this does raise a great possibility: An add-on product that could maintain a reasonable temperature in the car while displaying a prominent notice easily visible from the car’s driver and passenger windows. A solar-powered cooler that hangs inside the window perhaps? Any inventors out there? That’s a Kickstarter I could get on board with.

Seriously. Summer is coming. Don’t overheat your pups. Trade in for a Tesla today! (I wish …)

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.

Travel Pods for Pets?

Seasoned car travelers

I have quite a bit of travel coming up, and the plane trips require leaving Cali behind. So when I saw this article on Wired.com about a new travel idea, my mind went right to dog travel. Safe dog travel, not the current nightmare scenario.

The article is about an aerospace designer, working with Airbus, to create custom cargo pods with bunk beds. The airlines be shaped to put the special cargo pods aboard or not, depending on the needs for a particular flight. When used, they’ll be accessible to economy passengers who wish to rent a bed for the duration of a long flight. That means that there will be a way for passengers to move between the main cabin and the pod.

So … why not design a similar pod for dog kennels?

The article states that the pods are being designed for economy passengers, since business or first class fliers already get beds on long flights. The cost will have to be less than the cost of a first class ticket, or why bother, right? The article describes on other uses for these designable, modular pods: lounges, kids’ play areas, conference rooms.

So, seriously, why not kennel space? They’d need a way to secure the dog crates — not a problem since airlines that transport pets already do that. For any of the uses described, the pods would need to be climate controlled, have decent airflow, and be accessible from inside the plane. I personally would be much more comfortable flying my pet if I could spend the entire flight (other than takeoff and landing) with her, even if she had to stay in a crate. As for cost, well, a two-week vacation can already run about $500 (or more!) for dog-sitting; wouldn’t you rather spend that money to take your pet along? I would. And I’d certainly see value in flying Cali cross-country rather than subjecting her and myself to a weeklong car trip, should the need arise. (We’ve driven cross-country several times; Jana experienced about a dozen cross-country drives in her lifetime.)

I wonder why flying pets wasn’t one of the uses Airbus mentioned. Maybe I should suggest it!