U.S. Department of Transportation
Makes 3-part Recommendation
By Clarence Schadegg
As a blind person who
uses a service animal in my day-to-day activities, I am deeply
concerned with the U. S. Department of Transportation (DOT) three-
part proposal which will, if approved, violate my rights to fair
and equal travel on airlines. The U.S. Department of Transportation
three-part recommendation will have grave consequences for users
of service animals. The DOT has recommended that “If the service
animal does not fit, it should be re-located to another space in
the cabin if possible in the same service class. If no single seat
will accommodate you, you may be offered the option of purchasing
a second seat, traveling on a later flight, or having the service
animal travel in the cargo hold.” This is the Notice of Proposed
Rule Making published by the Department of Transportation in the
Federal Register on November 4, 2004.
I have some suggested changes to the DOT proposal, and they are:
1. Keep the service animal
user, along with their working dog, together in the same assigned
seat. If the person and their service animal have to move, put us
together in an alternative seat, either first or second class. The
travel agents who have booked my flights had me assigned in the bulkhead
seat so my dog would have more space to stretch out and relax. The
dog and the service animal user are a team, and some of us have many
years of a working relationship with our service animal. Separation
from our service animal is not an option.
2. Do not charge the
service animal user for the seat next to him or her because our
dog might be considered too big for the assigned space. It is ridiculous
to charge me for another seat because someone perceives my dog
as too big for the space at my feet. I’ve
flown many times and my large dog guide has never been an issue with
the people who were seated next to us. The airlines and the flight
attendants have been exceedingly supportive and helpful to me on
my flights across the U.S. It is unconscionable that if the DOT proposal
becomes a rule it will negatively affect my seating rights in future
flights.
3. It is unrealistic to assume
I will have the luxury to reschedule my flight at a later time. I
do have a life and I do have places I need to get to on time. It
is nonsensical for the DOT to expect me to take a later flight because
my dog is considered to be too big for an assigned seat. This recommendation
will make it harder for me to make my connections to catch other
flights when I have to travel across the country. It will also make
it impossible for me to keep my job as my employer will not understand
why I chose to schedule a later flight when I was expected to be
at work in another city at a specific time.
4. Lastly, it is equally unrealistic
to recommend that I put my service animal in cargo. My dog guide
is not a pet. The conditions in cargo are not safe for animals, and
I would not put my dog in such a dangerous situation.
“On February 1, 2001, President George W. Bush announced a
$1 billion plan to help Americans with disabilities. The purpose
of this program is to provide access to jobs, education and assistive
technologies by: Funding 10 pilot programs for the improvement of
transportation for people with disabilities.” (According to
the National Business and Diversity Council.)
The DOT proposal will
not help the disabled and the proposal will also limit our use
of transportation. How are those of us who use dog guides supposed
to meet our employment and/or education responsibilities if the
DOT proposal requests us to postpone our flight at a later time?
The DOT proposal puts us and our service animal at risk of injury
if our animal is put in cargo. I do not understand why the DOT
will take us backwards when so much money has been appropriated
to provide those of us with a disability better access to jobs and
transportation across the United States. The DOT plan contradicts
President Bush’s plan for disabled people to have access to
jobs, transportation and education. The DOT recommendations cited
above are unacceptable because such a change could negatively affect
the way I’m treated on future flights.
“The Air Carrier Access Act (ACAA) and the U.S. Department
of Transportation’s implementing rules prohibit discriminatory
treatment of persons with disabilities in air transportation.” (National
Business and Disability Council). However, the proposal by the DOT
is nothing less then discriminatory to those of us who are disabled
and users of service animals. Many of us who are disabled are already
marginalized because of our disability, and the DOT proposal will
make it harder for us to bridge the employment gap.
The DOT proposal is
a form of discrimination because this plan will result in a difference
between how disabled people are treated to that of non-disabled
people. These recommendations present a danger to service animals
and to the safety and mobility of service animal users. The DOT
proposal is also unrealistic since many disabled people are already
burdened with limited income and extreme costs in expenses in travel
and other basic life activities which some non-disabled people
take for granted. “Earned income represents only 71%
of the total income of people with disabilities, compared with 92%
for those with no disabilities. (U.S. Department of Labor). The 2004
Harris Survey of Americans with Disabilities, National Organization
on Disability cites, “Of all working ages of people with disabilities,
ages 18 to 64, only 35% are employed full or part-time compared to
78% of working age people without disabilities.
On Thursday, August 25, 2005, my wife and I boarded our return Northwest
Airlines Flight from the Biloxi Gulf Port Airport for Memphis and
Minneapolis. Imagine what would have happened to us if we were asked
to book another flight. I believe that if we delayed our flight two
or three days, neither of us would have gotten out alive because
of hurricane Katrina. If my dog guide was put in cargo, he would
probably have died as the heat index in the Gulf Port region of Mississippi
was in excess of one hundred and seven degrees. The heat and humidity
were also unbearable around the Memphis Airport. To expect such a
well trained animal like my dog guide to travel in such heated conditions
without water, protection from the heat and unnecessary exposure
to the elements is cruel at best. A dog guide is an extension of
the service animal user, and separation from our service animal will
put us at risk of injury.
Please support us in our effort
to stop the DOT from either implementing or enforcing this incredibly
discriminatory proposal. For further information, please contact
President Rebecca Kragnes of the Minnesota Guide Dog Users at rebeccak@tcq.net
