Our Air Carrier Access Act (ACAA) rulemaking resources include the following:
• An article on the design challenges and solutions for ACAA service animal access
• Our specific proposal for ACAA service animal flight access/accommodations
• Results from relevant community surveys (this page)
Avery & Béla are happy for your ideas to take flight!
Thank you to everyone who participated in our December 7th–10th survey for DOT, regarding the burdens associated with the current regulations’ medical documentation requirement. The results are presented in our report to DOT:
USAUSA ACAA SA DOT Info Request
This is also posted as a public comment in the Reg Neg docket:
https://www.regulations.gov/document?D=DOT-OST-2015-0246-0296
The previous survey closed on February 4th, 2016. Thanks to all of you who provided feedback on our proposal, taking advantage of this chance to make a lasting difference for all service dog handlers who ever need to travel by air!
What’s below is a little about our earlier efforts and survey. For a comprehensive view of what’s gone on so far with the latest updates, see our the page linked at the top of our ACAA resources listed above.
We try to work cooperatively to meet everyone’s needs, and the ACAA update process is no different. So we outlined six goals any proposal should respect. Those six goals are:
• Public safety through reasonable measures
• Fair and just disability access (mental health parity + no undue burden on disabled)
• Discouraging intentional and unintentional fraud
• Clarity and systematic ease of use for all parties
• Privacy of specific medical information
• Respect and liability reduction for airline and airport personnel as non-experts in disability access, animal behavior, and legal affairs
Our ACAA committee intensely debated to come up with a proposal to meet all these goals. The survey was about this proposal draft, which is linked above. Our community’s feedback works toward really important changes to the system!
For those interested in the thinking and justifications that led to our proposal, Brad Morris wrote an article that safely gets you across the sticky web of design challenges involved. Dig into the details—this link is also in the section at the top of the page. Note that PSDP was involved in authoring a reasoned compromise proposal through the USAUSA coalition after the Negotiated Rulemaking failed to reach consensus.
Survey results: 95.5% mostly or completely support the proposal (3.7/4 rating), 100% say it meets most/all of 6 universal stakeholder goals (3.6/4 rating)
Praise from survey-takers…
[PSDP’s proposal is] much more equal for all disabilities and won’t cost anyone anything more than the paper it is printed on. Pretty good compromise!
The system PSDP proposed is well beyond what I imagined. The measures are a drastic improvement beyond the current system: (1) fair to all service dog handlers, (2) standards that set the bar at exactly the right level for handlers, airport/airline employees, and the public, and (3) easily and cheaply implemented without any overbearing bureaucracy.
“This is a great proposal. I really like that service dogs in training are included. It is necessary to train your dog in airport and airplane environments[…]. I think it is a good way of meeting all the stakeholders’ needs and not infringing too much on the rights of people with disabilities using service dogs (or SDITs).”
“Succinct and understandable. Very well written!”
“The form and guidance clearly hail from an ethos of cooperation among all stakeholders, but even self-interested groups should take note and jump on board!”
In early March 2016, PSDP traveled to DC to begin collaborating with other groups.