In Response to Delta's New Service Dog Policy

Let me first say that I strongly empathise with airlines’ attempt to crack down on fake service dogs in order to protect the safety, health, and enjoyment (as much as there can be enjoyment on a plane) of the passengers on their flights. Fake service dogs are as much a hazard to me as to them, in different ways, and I really do think we need better regulation on that subject.

That being said…

Come on, Delta, you can do better than that!

Honestly, don’t you have at least a few HR and legal personnel and an entire disability assistance department to call on to help write these kinds of policies?

Ok, let’s back up in case you missed what I’m talking about.

A couple of weeks ago Delta Airlines announced a new policy to take effect on March 1 requiring people with service dogs to submit annual vaccination records and to check in with airline personnel and to travel with copies of their vaccination records, and a couple of other nitpicky details like that. Let’s count the problems with this policy.

1)             Requiring annual vaccination records means no last-minute flights.

2)             What am I supposed to do if I book through Alaska and then find out when I get to the airport that I’m being routed onto a contracted Delta flight for my second leg?

3)             Requiring in-person check-in is discriminatory, humiliating, and extremely inconvenient. What if I’m traveling in a group? Getting through airports takes me long enough as it is – why would Delta want to pile on additional time constraints by having a sizeable portion of its clientele required to wait in line rather than take advantage of their curb-side, kiosk, or online check-in to save time? IT’s costly to them, and me!

4)             Are these regulations the same for pet owners? No, no they’re not. Discrimination.

5)             Vaccination records are not the same as proving legitimate service dog status. The policy doesn’t actually do what it’s supposed to do.

Just off the top of my head, those five reasons come to mind. My email to the Department of Transportation, forwarded to Delta, was much more eloquent. The Seeing Eye sent out an email detailing some of their concerns, which overlap with mine, regarding the new policy. They asked us grads to email DOT to complain about the new policy. The DOT sends copies of complaint emails to the airline, which is required to respond within 30 days to the complaint. So, being the good, concerned and involved citizen that I am, I fired off an email to the DOT and waited patiently for Delta to respond. I got an email back within the week acknowledging the complaint and promising to review the policy in light of my concerns.

Seems I wasn’t the only one who complained, because within the next three weeks I received another email from Delta walking back a lot of their policies. I saw a lot of words like “encouraged to but not required” where there used to be “required.” I’ve included TSE’s summary and FAQ of the altered policy below, so you can see exactly what we dog teams are dealing with now.

Under the revised policy, still scheduled to go into effect on March 1, passengers with service animals will no longer be required to complete the check-in process at a Delta ticket counter. Instead, passengers will once again have the option of checking in electronically, at a kiosk or at curbside. Also, advance notice is no longer mandatory so you will be able to travel on short notice or transfer from another airline to Delta without restriction. However, Delta's new policy for service animals still requires you to "travel with the animal's Veterinary Health Form and/or an immunization record or other proof of vaccination."

Here’s a brief Q&A that may help answer some of your questions.

Q: What immunization record does Delta require?

A: Delta only requires proof of your dog’s rabies immunization. You are no longer required to show proof of a distemper vaccination. A valid rabies vaccination certificate from your veterinarian meets this requirement.

Q: What is Delta’s Veterinary Health Form?

A: Delta’s Veterinary Health Form is an alternative to a rabies vaccination certificate and can be downloaded from the company’s web site. If you choose to use this form, your vet has to fill it out with the date of your dog’s rabies immunization, the vet’s office info, and the vet’s signature. The form is valid for one year from the date the licensed veterinary professional has signed it. You must keep the original with you at all times while traveling. The form is available here: https://www.delta.com/…/TrainedServiceAnimal-RequiredForms.….

Q: Can I use my dog’s rabies immunization record instead of Delta’s form?

A: Yes, you may use your dog’s rabies vaccination record in lieu of Delta’s Veterinary Health Form as long as the vaccination date is valid during your travel, and the veterinary office information is included on the certificate. You can ask your vet for extra copies of your rabies certificate and simply keep one stored in your passport or luggage at all times.

Q: What “other proof of vaccination” will Delta accept as proof of rabies immunization?

A: According to an agent on Delta’s Disability Assistance Line, you may use your vet’s printout of services rendered as proof of rabies immunization as long as it is current within one year of your travel dates. There have also been questions about using your dog’s rabies tag as proof of vaccination. To date, we have been unable to confirm with certainty that a rabies tag can be used since we continue to receive conflicting responses from Delta’s Assistance Line agents. However, as is the case with the rabies tags issued by The Seeing Eye, many rabies tags only show the year when the vaccination was administered so it’s not clear if the tag would even be acceptable after that year ends, even if the vaccine is valid for three years. Given the apparent confusion among Delta representatives, and the lack of guidance about using rabies tags, you may wish to bring along your dog’s rabies certificate as a backup if you choose to use your dog’s rabies tag as proof of immunization.

Q: Why do I have to keep proof of rabies immunization with me while traveling at all times?

A: Delta has not shared a reason for requiring proof of vaccination, nor has the airline shared when, or by whom, passengers can be asked to show this documentation.

Q: What can I expect when flying on Delta in the near future?

A: Graduates flying on Delta in the immediate future may encounter some confusion among airline representatives as Delta’s new policies for service animals and emotional support animals are rolled out. One way to help the process go more smoothly is to immediately identify your dog as a service animal that has been specially bred and trained to mitigate your disability. Also, be sure that you understand your rights, and if you are prohibited from checking in online, at a kiosk, or at curbside, immediately ask to speak with a CRO (Complaint Resolution Official). You can read more about your rights at: http://www.seeingeye.org/…/r…/airlines-and-cruise-ships.html.

Now, I usually fly Alaska because they have a couple inches extra room per seat and that’s a big deal when you’re sharing a seat with a German shepherd. Yes, they do tend to be semi-liquid substances capable of compressing, and then expanding to fill all available space. But that still cuts into my leg room, and I have long legs. Alaska also has a rewards program that works for me, so they’re my preferred airline. But they don’t fly out of my city. I usually take a Delta flight to Atlanta, then an Alaska flight from there. I am not looking forward to the confusion pending with my next flight. Given the rapid turnaround of policy changes I fully expect the gate agents to have no idea what they’re supposed to do with me. Now, I’ve never had a bad experience at this airport; the ticket agents and gate agents are lovely people, and I fly often enough and am recognizable with my dog that a few of them have begun to recognize me when I show up. But this kind of policy change is going to raise tensions as they attempt to walk the line between fulfilling policy requirements and not making unintentionally discriminatory mistakes in enforcement. I’m going to have to do some thorough research before my next flight to make sure I stay abreast of all relevant policy changes and citizen rights to make sure that I can be politely firm and well-informed. Thank you, Delta, for making my life more complicated than it needs to be. I understand where you’re coming from but…

Don’t you have people who should consult on this kind of policy and catch the problems before you let your PR guy spit it out? Couldn’t you consult with advocacy agencies to collaboratively develop a policy that suits all parties involved? We want more controls on the fake service dogs, the poorly behaved service dogs, and poorly behaved pets as you do! We’re on the same side!

It’s on my to-do list today to write a letter to Alaska to ask them to be more thorough if they consider their own version of the Delta policy. I don’t want to have to juggle multiple confusing airline policies. Having a permanent physical disability that interferes with activities of daily living (ADLs, just learned that acronym in one of my psychology classes0 is difficult enough; I do not have time to become a legal expert on airline travel.

In response to this, and the growing concerns over service dog regulation, or lack thereof, the seeing Eye has decided to employ a full-time advocacy expert. Previously the job was performed on a volunteer basis by members of the staff, but now there is a position posted for it here. If you have the qualifications and don’t mind New Jersey, I still encourage you to apply. It’ll be a very rewarding and impactful job full of new challenges and the opportunity to positively affect thousands of peoples’ lives.

Now, for those of you who’ve been reading my blog for a while, you know I don’t throw words like “discrimination” out there a whole lot. I think it’s a powerful word that has been diluted by overuse, and so I reserve it for when it is actually appropriate. In this instance, however, I believe it is relevant. Delta’s attempt at segregating service dog handlers discriminates against our right to equal access and treatment, and actively makes life more difficult for us. However, we live in a country where people like me have the right and mechanism to communicate with both the government and the corporate entity causing the problem, to engage in a productive conversation about problems we are experiencing, and actively participate in their resolution and the prevention no future problems. For this I am immeasurably grateful to God, to the Founding Fathers, and to the heroes of the Civil Rights Movement and all those that paved a smoother path for me. I will not dishonor their work by complaining about every employee of every business who asks if I have a service dog or talks to my husband instead of me when asking that question, but I will honour their work by refusing to compromise my rights and capabilities for their convenience. After all, I am not the last service dog handler or blind person to walk this earth; the choices I make now are a positive or negative investment in the future of all disabled people and I take that responsibility very seriously.

Delta, thank you for listening. Do your homework before class next time.

Friends and family, thank you for participating in the campaign to show Delta the terror of its ways.

TSE, thanks for fighting for us so hard and teaching and encouraging us to fight for ourselves.

God, thank You for the incalculably valuable gift of communication that makes this system possible.