Orly’s First Camping Adventure

Cali and Oly, both golden retrievers, play in a rocky creekOrly and Cali spent a chunk of Labor Day weekend at the Grizzly Campground in Montana’s Lolo National Forest. It was Orly’s first camping adventure, so Cali had to show her the ropes a bit. Not that Cali has a lot of experience … she may have exaggerated a bit when telling Orly her campfire stories.

A view of sunset and trees from the tent window
The view from the tent window

They did not get their own tent; we all shared. Our tent has a huge window, and Orly spent most of the first night looking out the window at the treetops and the stars. We were all pretty relieved that she did not spot any bears.

As the temperature dropped overnight, the girls crept closer and closer, until we were all cuddled into a single mass. They also tried to steal the sleeping bag.

Both girls spent hours hiking, running along the trail and splashing in Rock Creek and Ranch Creek. They gnawed bones, wrestled, grumbled at the dogs in the neighboring campsites, and gobbled treats.

Cali and Orly lick a bowl clean
The girls helped with the dishes

It wasn’t all play, of course. In addition to their responsibility to watch for bears and supervise meal prep, the girls had chores. They energetically tackled keeping the campsite “floor” clean, for example, by removing all sticks, pine needles, and dirt — and unselfishly carrying it around in their fur. Cali does have extensive experience with this and could be seen coaching Orly in the finer points of the roll, with tips on how to wriggle the hips and shoulders just so for maximum pickup efficiency. They also helped clean the dishes after every meal.

Needless to say, their first activity upon returning home was a bath. That may have soured them on future camping trips, but I doubt it!

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A Win for Service Dogs!

Koala, a black Lab, studies her iPad
Koala is booking her next flight

The Department of Transportation released its new rules regarding travel with service dogs. This long-awaited ruling amends the Air Carrier Access Act’s (ACAA) regulations on travel with service animals. The 122-page ruling is available on the DoT website. An FAQ is also available. More than two years(!) have passed since DoT first requested public comment.

The ruling is worthwhile reading. It describes several issues considered and summarizes the comments and arguments presented around each. I’ll summarize some of the key points here, and let you delve into the details on your own.

The new rules take will effect January 11, 2021, after publication in the Federal Register on December 10, 2020.

1. Alignment with ADA on definition of a service dog

The ACAA has adopted similar wording and a similar approach to the ADA (Americans with Disabilities Act) in defining 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.” More significantly for the traveling public, the ACAA is doing away with any requirement that airlines allow passengers to bring so-called Emotional Support Animals (ESAs) on board without paying a pet fee.

It also requires that airlines treat psychiatric service dogs the same way it treats other service dogs. Many airlines had treated these as ESAs and/or required additional documentation or other “hoops” for passengers traveling with psychiatric service dogs.

The amended ACAA excludes miniature horses from travel in the cabin of an airplane.

2. New paperwork requirements

The new ruling includes a paperwork requirement for all travelers with service dogs. Using the DoT official Air Transportation forms, each traveler who is accompanied by a service dog will be required to attest that the dog has been trained to assist with a disability, the dog behaves safely in public, and the dog is in good health and current on vaccines. If the traveler has any flight segments that are eight hours or longer, they must further attest that the dog “has the ability either not to relieve itself on a long flight or to relieve itself in a sanitary manner” (what counts as sanitary is unspecified).

Airlines can require that the traveler provide the forms up to 48 hours in advance of the flight if they’ve made their flight reservations by then. Airlines cannot, however, require that passengers traveling with service dogs check in earlier than other passengers or check in in-person. If a traveler’s reservation is made within 48 hours of departure, the airline can require the passenger to present the completed forms at the departure gate.

3. About the dog

Airlines may limit a passenger to two service dogs. Whether the passenger has one or two service dogs, though, dog(s) and human must all fit within the space of the handler’s seat and foot space on the aircraft. And they can require that the dog be “harnessed, leashed, or tethered” at all times in the airport and on the aircraft. This is a departure from the ADA, which makes allowance for unrestrained service dogs if that’s necessary for their work. The rationale given in the ruling references the unique environment of an aircraft and situation of being in close quarters, in a stressful environment, with no escape.

If a service animal is too large to fit in the passenger’s space, the airline must offer to move them to another seat with more space, if one is available in the same service class; move them to a different flight; or transport the dog in the cargo hold.

Airlines are not allowed to ban a service dog based on its breed (though some are still trying to do so). But any dog can be excluded from a flight if they exhibit aggressive or unsafe behavior.

A win for pets, too

These new rules aren’t perfect and won’t solve all the problems working dogs face when confronted by fake or poorly trained service animals, but removing ESAs from the picture will certainly reduce the frequency. The numbers are staggering — Airlines for America, an airline trade association Deni found recently while doing research, concluded that more than a million air travelers brought their ESAs aboard in 2018. The number of websites where pet owners could purchase “credentials” transforming their pets into ESAs, while also conveniently purchasing official-looking vests and tags, grew in a trajectory similar to the number of traveling ESAs, while the number of passengers paying pet fees plummeted.

Many of these pets, as I have written before, receive no training and are terrified when taken from their usual safe home life into the bustle of an airport, the stress, along with strange noises and smells, of an airplane, and then, too often, removed from their carriers to be clutched by their anxious owners who are somehow comforted by the presence of their traumatized pets. Not surprisingly, the number of complaints about scared animals doing what scared animals do had climbed as the number of ESAs skyrocketed. The DoT fielded 700 complaints in 2013 — and 3,000 in 2018, according to Deni’s research. These range from animals eliminating on planes to snapping, nipping, and serious bites.

Dogs trained by reputable trainers or guide- or service-dog training schools receive many hours of public-access training and pass rigorous evaluations. But not all service dogs are trained that way. And some dogs are fine in 99% of public settings but are terrified by air travel. So the new law is not a guarantee that the dog in the next seat will be as perfect as Lassie. But, while it doesn’t close every loophole or solve every problem, the new restrictions are likely to make working-while-traveling a lot safer for thousands of guide and service dogs — and their human partners.

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.

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.