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Democratic senators call for digital update to Department of Transportation’s service animal flight form

Sens. Ron Wyden of Oregon and Tammy Duckworth of Illinois recommend that the DOT update its service animal commercial flight form for better accessibility.
Jan. 11, 2023 -- An American Airlines Airbus A321 airplane takes off past the air traffic control tower at Ronald Reagan Washington National Airport in Arlington, Virginia. (Photo by SAUL LOEB/AFP via Getty Images)

The Department of Transportation has created “unacceptable barriers” for individuals who need to travel with service animals by forcing them to fill out “inaccessible, demeaning and time-consuming paperwork” instead of having a true digital option, two Democratic senators said in a letter shared Wednesday with FedScoop. 

Sens. Ron Wyden, D-Ore., and Tammy Duckworth, D-Ill., released the letter to DOT in response to a request for comment that the department posted in November, advising the agency to make the online form more accessible to users. 

These recommendations included the offering of a web-based form, removing “redundant and threatening” legal warnings from the existing form, removing duplicative fields and allowing passengers to opt-in to using previously filed paperwork so travelers do not have to resubmit for each flight. Wyden and Duckworth also recommended a helpline for those who have issues with DOT’s forms.  

“The first step is to see if DOT listens to Sens. Wyden and Duckworth and folks who represent disabled Americans [or] listen to disabled Americans about their needs and if they listen to that feedback and incorporate it,” a Wyden aide said in an interview with FedScoop. “If not, then it really depends on what the Transportation Department does as far as what Wyden’s next steps are.”

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In the letter, Wyden and Duckworth cite the burdens placed on those who need to travel with their service animals, such as currently offering the required form in a PDF format, one that the legislators call “particularly difficult to access and interact with when using mobile devices or screen readers and other assistive technology.” Currently, the department only encourages airlines to use accessible web formats, like HTML, for the form.

The document cites the agency’s noncompliance with the Office of Management and Budget’s requirements of the 21st Century Integrated Digital Experience Act, which requires government websites to be accessible for those with “diverse abilities,” and warns against publishing content in a PDF format.

“There are a lot of laws already on the books mandating use of accessible technology, but just looking at this form as an example, those rules and those policies aren’t always followed,” the Wyden aide said. “So trying to make sure that agencies are able to follow that guidance and able to make things accessible to folks who need them is really important, and it’s something I think Congress in general and the government in general needs to focus on.”

Issues with DOT’s service animal form for commercial flying is “amplified” since the agency allows airlines to require travelers to complete and resubmit a new copy of the paperwork before every trip, regardless of whether the information has changed in between flights, according to the letter. 

The agency previously cited privacy implications in the final rule as a reason for allowing new copies to be required before every trip, stating that this would mean storing and maintaining an individual’s service-animal information on their travel profile “without the passenger’s consent.”

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To remedy this, Wyden and Duckworth suggested that requiring stored information about a traveler’s animal-service attestation be optional, and only stored for a year in a database. The lawmakers point to American Airlines, which provides a yearlong, unique service animal number so that passengers do not have to resubmit the form for every trip. 

The Wyden aide said that the senator is interested in pursuing accessible, digital services further, but that it was too early to make any other announcements. 

“It’s a little too soon to talk about other services or other agencies, but I think if you talk to folks in the disability advocacy community, they’ll tell you that this is not limited to one form at the Transportation Department,” the Wyden aide said. “It’s really widespread, government websites, government services. There definitely is an interest to continue to do oversight on this issue.”

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