Skip to Content

Red Alert: Act Now to Stop Regulatory Threat to Air Travel for Blind Guide Dog Owners!

February 16, 2005 • Darrell Shandrow Hilliker

Proposed regulations by the United States Department of Transportation would require the blind and others who rely on large “service animals” to deplane or ship their companions in the cargo hold! All who care about the blind and others with disabilities MUST act immediately to stop this threat by having the proposed regulatory language changed to allow alternatives that will reasonably accomodate people with disabilities.

What can you do now? Read the Emergency Call to Action sponsored by the International Association of Assistance Dog Partners and submit a comment to the Department of Transportation insisting that the language of the new regulations require the airline industry to reasonably accomodate blind guide dog owners by taking actions such as making voluntary arrangements or moving passengers instead of harming the blind by forcing us off the plane or separating us from our dogs. Everyone who sincerely cares about the blind will take this action immediately!

The following are the public comments I submitted to the Department of Transportation’s Docket Clerk:

February 16, 2005

Docket Clerk

Department of Transportation

400 7th Street, SW., Room PL-401

Washington, DC 20590.

DOCKET NUMBER: OST-2004-19482-1

Dear Docket Clerk,

I am a highly accomplished blind information technology professional, accessibility advocate and publisher of the Blind Access Journal. My girlfriend is a blind professional in the resort hospitality industry who also happens to rely on a guide dog to meet her independent travel needs. We both travel on airlines for business and pleasure from time to time.

I am deeply troubled by dangerous language in the NPRM relating to large service animals that might not fit in front of the passenger’s seat or even in the bulkhead area. Persons with disabilities who rely on such “large” animals cannot rightly be expected to allow their companion to be placed in the aircraft’s cargo hold or be forced to wait for a later flight where the same situation might exist. Since we pay our hard earned money to travel just like everyone else, these undue regulations represent a reduction in the service levels we receive in comparison to customers without disabilities. They would also simply represent an ethical, moral and, perhaps, legal violation of our rights as fully living and breathing human beings and citizens of the United States of America, with all the rights and responsibilities that first class status entails. In a case where a guide dog does not fit in the typical spaces, alternatives must be considered that do not result in undue harm to the disabled person or their service animal. Alternatives might include moving either the person with a disability or a nondisabled person sitting in the adjacent seat to accomodate the service animal, even if that entails moving the passenger to seating in a different part of the cabin such as business or first class. Denial of service to a person with a disability is never appropriate under any circumstances.


Darrell Shandrow
Blind Access Journal:

Categories: Uncategorized

5 opinions on “Red Alert: Act Now to Stop Regulatory Threat to Air Travel for Blind Guide Dog Owners!

  1. Before you wrote to the DOT, did you investigate this a little further or are you just running with “heresay”? I would suggest that you check your information before you start complaining. Just because you read something on the internet or heard something on the radion doen’t mean it is true. I have several friends and associates who are executives in large corporations and travel often. They also happen to be blind and have guide dogs. They have never experienced ANY problems travelling with their dogs and feel you may be a little mis-informed. However, if AFTER you have checked your facts, it does reveal that the DOT is planning to adopt this regulation, then I applaud all your efforts to get people involved to fight this.

  2. It appears the dockett number in my article was incorrect. I corrected the 8 to 9. Following the instructions on IAADP’s web site, I believe I did use the correct number when submitting my public comments. It does appear that we are technically outside the deadline, but additional comments will apparently be considered. All currently available information about this dockett is available at the following link on the Department of Transportation web site: anything, it seems I didn’t get this information soon enough. I hope we can still make a difference!

  3. The President of the International Association of Assistance Dog Partners is Dr. Ed Eames. Ed and Toni Eames are guide dog owners and have been involved in the blind community at levels of trusted leadership for many years. IAADP is a legitimate, trusted advocate for the rights of assistant dog owners around the world.

    My anonymous attacker claims that I am misinformed, that I have not considered all the facts before posting my “red alert” requesting that everyone file their comments with the Department of Transportation asking that they avoid violating our rights. The initial article contained a link to IAADP’s call to action and another to a page giving instructions for filing the comments. I have since posted an additional comment providing a link to the Department of Transportation’s Notice of Proposed Rule Making concerning the issue at hand.
    It is my sincere hope that you will go ahead and file the comments, that you won’t allow yourselves to be derailed in your convictions for equality by my attacker, who won’t even give his or her name. Though I hope it isn’t true, there is always the possibility that the anonymous poster is employed with the airline industry or another agency, company or organization advocating for a position that is altogether opposed to us. I strongly urge the anonymous poster to clarify the intention of his or her comments and to provide any and all solid information that would be helpful in our bid to retain the right to travel on airlines with our guide dogs without undue interference.

  4. Karen submitted the following comments to the Department of Transportation concerning the NPRM:

    February 23, 2005

    Docket Clerk

    Department of Transportation

    400 7th Street, SW., Room PL-401

    Washington, DC 20590.

    DOCKET NUMBER: OST-2004-19482-1

    Dear Docket Clerk:

    I am a blind individual whom depends on a dog guide for traveling. This is my third dog & I have been a dog guide user for approximately 14 years. I have also been traveling on aircraft for a number of years with my dogs.

    It has been my observation that there is not currently as much room for the dogs in the bulkhead seating area in comparison to the 1980’s and early 1990’s. In the last decade, the airlines have increased the number of seats while decreasing the space available for all passengers. Though it is, perhaps, cost effective for the airlines, cramped seating does not consider comfort level & quality of service for all passengers, especially for disabled customers traveling with service animals or those whom rely on wheelchairs & other devices for their mobility needs.

    I am employed in the Hospitality Industry and, thus, work in a
    “service field “. The Airlines are also a service occupation &
    should be treated as such. It is vital to consider the needs of all passengers, including those of us whom travel with dog guides. These dogs are not just our eyes, but are companions. It is a partnership & each team depends on the other for guidance & support.
    It is unacceptable & an unreasonable accommodation to expect the person
    & service animal to be separated from each other.
    Moreover, it is just as unreasonable to expect the dog to have to be under the seat for hours at a time, to be cramped or possibly injured because other passengers are not aware that the dog is under the seat. It is inappropriate to limit or eliminate reasonable accomodations such as an adjacent passenger moving to another seat or for the blind person to move to another seat, even if a different class of service must be provided in the process. Forcing disabled passengers with service animals to deplane without providing reasonable accomodations is never acceptable under any circumstances.

    It is imperative that the language in this NPRM be modified in such a way to reasonably accommodate all passengers traveling with service animals. This should be a quality of service issue, not solely an economic concern for the airlines. If each carrier provides exceptional customer service, considering all needs of their passengers, then, those customers will continue to fly the friendly skies with the carrier that provides the best quality service & meets their needs. This makes
    good business sense.

    Needless to say, please, address our concerns & provide us “reasonable accommodations”. Do not expect us to put our dogs in the cargo or deplane. This is unacceptable.

    It is understood that some passengers are bringing their pets on board the aircraft claiming they are service animals. I would recommend that you consider expecting the airlines to check for harnesses or other signs that it is a service animal or ask for identification from the dog guide school or facility where the dog received training to determine whether the animal is a legitimate service animal.
    Just as ticket agents expect us to have identification to prove we are
    who we say we are, the staff needs to verify the identity of the service
    animal as well.

    My dog Douglas weighs 65 pounds, & though he is an average size guide
    dog, he does not technically fit under the seat and his size extends
    beyond the boundaries for what the NPRM now appears to consider acceptable without representing an “undue burden” to the airline.
    Please consider the recommendations of guide dog owners, schools and others in the blind community by comprehensively addressing our concerns. This is
    a significant issue that can & will affect the lives of the blind &
    other disabled and their service animals.


    Karen Hughes
    Resort Hospitality Professional and Correspondent, Blind Access Journal

Leave a Reply

Your email address will not be published.