GDB Comment on Service Animal Air Transportation Forms

The U.S. Department of Transportation (DOT) has requested public comments on renewing its Service Animal Air Transportation Forms attesting to the health, training, and behavior of guide dogs for air travelers. These are updated versions of the forms implemented in 2021. You can see GDB's original position on these forms in our initial response to the DOT's 2020 Proposed Amendments to the Air Carrier Access Act.

The DOT forms have been, and continue to be, frustrating obstacles for air travelers with guide dogs. While DOT has improved the forms in the attached files, consistent feedback from GDB’s graduates singles out the need to submit the form as an unfair burden on guide dog handlers. We strongly urge DOT to exempt travelers with guide dogs from the requirement to submit the form. 

GDB strongly encourages all graduates to comment on the renewal. Comments must be filed by May 29, 2024. We’re a small community, and your voice is critical. 

How to file your comments with the Department of Transportation 

Online:
Visit Regulations.gov.

Docket number DOT-OST-2018-0068

Mail:  

Docket Management Facility,

U.S. Department of Transportation

1200 New Jersey Ave., S.E.,

West Building Ground Floor Room W12-140, 

Washington, DC 20590
 

Hand Deliver:
West Building Ground Floor, Room W12-140

1200 New Jersey Ave. SE, Washington, DC 20590 

Between 9 a.m. and 5 p.m., Monday through Friday, except Federal holidays. 

The telephone number is 202-366-9329.
 

Guide Dogs for the Blind Comment: DOT Behavior and Health Attestations Forms

Docket number DOT-OST-2018-0068

Guide Dogs for the Blind was established in 1942 in California to support blinded World War II veterans.  As the largest guide dog school in North America, we are proud to have served 16,000 clients in the past eight decades out of our California headquarters and our more recently established campus in Oregon.  Our highly selected and trained dogs have a life-changing impact on our graduates, helping to enhance their safety, mobility, and community inclusion. With the support of their trusted guide dogs, our graduates can live the lives they want to live, pursuing educational and job opportunities and experiencing greater dignity as contributing members of society. 

Guide Dogs for the Blind appreciates the Department of Transportation’s (DOT) continued consideration of the needs of disabled air passengers with service animals.  We praise DOT’s productive process of reaching out to stakeholders to improve existing regulations through more thoughtful implementation practices. 

Although the DOT Service Animal Air Transportation Forms highlighted the logic behind allowing service dogs in aircraft cabins, most of Guide Dogs for the Blind’s graduates have come to dread filling out these forms as burdensome and prejudicial. Locating, completing, and submitting the forms according to the varying airline guidelines, keeping up with when to update them for which airlines, and keeping track of paper copies when traveling all disproportionately impact passengers who are blind. 

We respectfully ask that blind and visually impaired travelers with service dogs be exempted from having to submit the DOT forms.

We appreciate DOT’s efforts to improve the forms’ format and clarity. Nevertheless, the burden of filling out these forms for passengers with guide dogs outweighs the benefits, making travelers with guide dogs feel like unwelcome customers. Meanwhile, the practical utility of the DOT forms airlines collect from guide dog handlers is negligeable. GDB is willing to work directly with airlines to find solutions and work toward a less onerous way to attest to the validity of a passenger’s service dog.

In balance, the forms’ impact on travelers with guide dogs is unreasonably high. 

We fully agree that service animal handlers should be in full control of their animals at all times, and wholly responsible for them.  Service animals should always be harnessed, leashed, or otherwise tethered in the airport and when on board an aircraft.  Handlers should be fully responsible for caring for their service animals, including feeding, watering, and relieving.  Handlers may be charged for property damage caused by their animals.  We support the rights of airline staff to remove dogs that are not fully under their handlers’ control, with or without a form on file.  We support the rights of airline staff to exercise some discretion in ascertaining whether an animal poses a threat or other problems on board. 

Regardless, the DOT forms relating to guide dog handlers have become a discriminatory set of regulations against people who have visual impairment. They deny U.S. citizens with disabilities equal consideration for ease of travel, restricting their livelihood, job opportunities, family connections, and civic engagement. Requiring unnecessary documentation is an unacceptable barrier for disabled air passengers with legitimate guide dogs. 

In summary, we fully support DOT’s efforts, for the safety of everyone, to keep untrained and poorly behaved dogs out of aircraft cabins. We are equally concerned, however, about the undue hardship the DOT’s service animal forms are causing our graduates and other guide dog handlers. We urge DOT to exempt passengers who are blind and visually impaired from the requirement to fill out these forms.