Last week, the U.S. Department of Transportation (DOT) released a Notice of Proposed Rulemaking (NPRM) related to transporting service and emotional support animals under the Air Carrier Access Act (ACAA).
Among other provisions, DOT proposes to define service animals as dogs that have been individually trained to do work or perform tasks for the benefit of a qualified individual with a disability. This could include physical, sensory, psychiatric, intellectual, or other mental disabilities. The proposed rule also would:
- Permit airlines to recognize emotional support animals as pets, rather than service animals
- Allow airlines to require passengers with a disability who are traveling with a service animal to complete and submit to the airline forms developed by DOT attesting to the animal's training and good behavior, certifying the animal's good health, and attesting that the animal has the ability either to not relieve itself on a long flight or to relieve itself in a sanitary manner
- Clarify existing prohibitions on imposing breed restrictions on service animals
- Allow airlines to set policies to limit the number of service animals that one passenger can bring aboard an aircraft
- Require service animals to be harnessed, leashed, or otherwise tethered
The notice also addresses the transport of large service animals in the aircraft cabin and clarifies when the user of a service animal may be charged for damage caused by the animal.
Veterinary expertise and feedback are crucial
Airlines and the DOT have both welcomed the AVMA’s voice in discussions on this issue, recognizing that the association’s voice is that of our 95,000-plus member veterinarians. The AVMA's prior comments on this topic, as well as the 2018 roundtable convened at AVMA headquarters, are mentioned at some length within the notice issued by DOT.
Add your voice
The AVMA will continue to represent the profession in these conversations by responding with comments on the DOT proposal. In doing so, we’ll continue to look to you for input. We welcome and encourage all interested AVMA members to submit feedback to us to inform our response to the DOT.
Please review the NPRM and email your feedback to PolicyandPracticeavma [dot] org by February 29, 2020. Discussion of the DOT's proposed forms, including those to be completed by the owner and those to be completed by the veterinarian, can be found on pages 64 through 70, with a model health form provided on page 71.
We look forward to hearing your thoughts.