After receiving so many comments to my Wednesday post about service dogs, I phoned Melissa Allman, Esq,, the Advocacy and Government Relations specialist at Seeing Eye. I thought you blog readers would be interested in seeing what their take is on the plans to amend and clarify regulations implementing the Air Carrier Access Act, and she gave me permission to share the text of their comment here:

Whitney’s graduation picture. (Courtesy The Seeing Eye.)

The Seeing Eye has been providing specially bred and trained guide dogs for people who are blind or have low vision since 1929. Since that time, The Seeing Eye has worked tirelessly to advocate for the rights of guide dog users to have equal access to all modes of transportation including air travel. At present, there are over 1,700 active Seeing Eye graduates in North America and many of those people are regular air travelers. As Senior Advocacy Specialist and a guide dog handler myself, I am submitting the below comments on behalf of The Seeing Eye. I commend DOT’s efforts to amend and clarify its ACAA regulations to ensure safe and equal access to air travel for people who work with service animals. The Seeing Eye’s position on the questions posed in the ANPRM is as follows:

Question 1: Whether psychiatric service animals should be treated similarly to other service animals; Question 2: Whether there should be a distinction between emotional support animals and other service animals;

Comments to questions 1 and 2: Service animals should be defined as those that are 1) individually trained to do work or perform tasks for a person with a disability and 2) public access trained. Animals that do not meet both of these criteria should be designated as a separate and distinct category from service animals.

Question 3: whether emotional support animals should be required to travel in pet carriers for the duration of the flight;

Comment: Animals should be permitted to travel in the cabin without being crated as long as they meet the criteria in the definition of service animal proposed in comments 1 and 2.

Question 4: Whether the species of service animals and emotional support animals that airlines are required to transport should be limited;

Comment: With respect to the species of service animals, the amended DOT regulations should be consistent with the Department of Justice regulations implementing the Americans with Disabilities Act. The result would be that the species of service animals would be limited to dogs and in some narrow circumstances, miniature horses.

Question 5: whether the number of service animals/emotional support animals should be limited per passenger;

Comment: The Seeing Eye is concerned that as the number of service animals traveling with a handler increases, the likelihood that the handler will be able to effectively control the animals decreases.

Question 6: Whether an attestation should be required from all service animal and emotional support animal users that their animal has been trained to behave in a public setting;

Comment: No. An attestation would have no value because passengers could provide assurances that the animal is trained to behave appropriately in public regardless of the animal’s actual behavior and there would be no way to determine the veracity of these statements. Existing guidelines allow airlines to refuse to transport service animals that are engaging in disruptive or threatening behavior such as excessive barking, biting, growling, jumping, eliminating in the terminal or aircraft, etc. Furthermore, if the definition of service animal is limited to those that are trained to perform work or tasks and public access trained, and all other animals were required to be in pet carriers, airlines would be far less likely to have problems with unruly or aggressive animals.

Question 7: Whether service animals and emotional support animals should be harnessed, leashed, or otherwise tethered;

Comment: Service animals should be leashed or otherwise under the handler’s control at all times. There are times during air travel when it may be appropriate for a passenger using a guide dog to remove its harness for the comfort and safety of the dog. However, the guide dog handler still has control over the dog in these limited circumstances because the leash is the means of control.

Question 8: Whether there are safety concerns with transporting large service animals and if so, how to address them;

Comment: If DOT adopts the definition of service animal proposed in comments 1 and 2, these safety concerns would be greatly decreased. On page 34, The ANPRM states in part that “Airlines have … expressed safety concerns about large service animals in the cabin, particularly large emotional support animals that have not received disability-mitigation training. … While the Department previously concluded that a service animal’s reasonable use of a portion of an adjacent seat’s foot space does not deny another passenger effective use of the space for his or her feet and is not an adequate reason for the carrier to refuse to permit the animal to accompany its user at his or her seat, some airlines have indicated that passengers feel pressured to agree to such an arrangement and have later expressed to airline personnel their dissatisfaction at having to share their foot space.”

If DOT requires air carriers to transport only dogs that are trained to mitigate a disability and behave appropriately in public, it will be easier for air carriers to simultaneously accommodate passengers using service animals and assuage the potential concerns of passengers who are being asked to help make that accommodation possible.

Question 9: whether airlines should be prohibited from requiring a veterinary health form or immunization record from service animal users without an individualized assessment that the animal would pose a direct threat to the health or safety of others or would cause a significant disruption in the aircraft cabin;

Comment: Yes. Airlines should be prohibited from requiring a veterinary health form or immunization record from service animal users in advance of travel. This requirement would place burdens and restrictions on service animal users that are not placed on other passengers. For example, the requirement could prevent service animal users from traveling on short notice or checking in on line or at curb side. Moreover, once an air carrier has made an individualized assessment that a service animal would pose a direct threat or cause a significant disruption in an aircraft cabin, veterinary records do nothing to mitigate the threat the animal potentially poses and DOT regulations do not obligate air carriers to transport the animal under those circumstances.

In closing, The Seeing Eye expresses its appreciation to DOT for the opportunity to participate in the advanced rule making process on an issue that is of paramount importance to our organization as a whole and our graduates as individuals. If The Seeing Eye can provide any further assistance or information on issues raised in this ANPRM given our areas of expertise, please feel free to contact us.

Melissa R. Allman, Esq.
Senior Specialist, Advocacy and Government Relations The Seeing Eye

A small dog yipped and lunged at wonderful Whitney the Seeing Eye dog when we checked in at Midway Airport for our flight to New England last month. No one got hurt in the run-in, but it was alarming. When Mike shared some of the highlights of that trip in his Mondays with Mike post last week, I was relieved he decided not to write about the incident at Midway – I approve his efforts to keep his blood pressure under control.

Whitney knows what to do on an airplane.

When we got to the gate, that same small dog barked and lunged at Whitney again. Just our luck: the yippy dog and its owner were going to be on our flight. I know to ready myself for distractions from other dogs when I’m outside with Whitney, I just forget that I have to be prepared for dog distractions inside airports now, too. Mike told me that the dog who’d lunged at Whitney was wearing a vest that said “Service dog in training” and he wondered out loud whether we should ask the owner if it’s possible for a dog like that to flunk out (a  great number of dogs bred and trained to become guide dogs never make it — simply barking in public or growling during training, for example, can result in what guide dog programs schools euphemistically call a “career change”).

Anyway, instead of asking the owner about any grading system for her dog, I opted for the two questions federal law allows businesses to ask people claiming their dogs are service dogs: “Is that a service dog?” and “What tasks or work does your dog perform for you?” The owner answered “yes” to the first question, then told me the dog keeps her calm and prevents her from getting panic attacks. Another woman at the gate had another smallish dog on a leash — that dog also had a vest on that said “service dog” –and when Southwest announced that people with disabilities could pre-board, both woman rushed to the front of the line to grab the bulkhead seats.

I sat in the 8th row window seat, Whitney, a 60 pound Yellow Lab/Golden Retriever cross, sat with her bottom under the seat in front of us, her head on my feet, and didn’t make a peep during the flight. When I stood up with her after we landed, the couple who’d been sitting in the row in front of us complimented Whitney’s good behavior. “We didn’t even know there was a dog behind us!” they marveled.

“She’s a service dog,” Mike responded with a shrug. “She was trained to behave in public.” I waited for the two dogs in the bulkhead seats to leave before giving Whitney the “Forward!” command. And then? My Seeing Eye dog calmly led me off the plane.

In light of the challenges people working with service animals are facing during air travel, The U.S. Department of Transportation (DOT) is making plans to amend and clarify its regulations implementing the Air Carrier Access Act. DOT has issued an Advanced Notice of Proposed Rule Making (ANPRM) and is seeking comments from the public on these specific issues:

1. Whether psychiatric service animals should be treated similarly to other service animals.
2. Whether there should be a distinction between emotional support animals and other service animals.
3. Whether emotional support animals should be required to travel in pet carriers for the duration of the flight.
4. Whether the species of service animals and emotional support animals that airlines are required to transport should be limited.
5. Whether the number of service animals/emotional support animals should be limited per passenger.
6. Whether an attestation should be required from all service animal and emotional support animal users that their animal has been trained to behave in a public setting.
7. Whether service animals and emotional support animals should be harnessed, leashed, or otherwise tethered.
8. Whether there are safety concerns with transporting large service animals and if so, how to address them.
9. Whether airlines should be prohibited from requiring a veterinary health form or immunization record from service animal users without an individualized assessment that the animal would pose a direct threat to the health or safety of others or would cause a significant disruption in the aircraft cabin.

This week the Seeing Eye sent an email message to its 1700+ graduates urging us all to contact DOT with our own comments. The Seeing Eye was at the forefront of making it possible for blind people to travel with trained guide dogs, and they’ve already weighed in with responses to DOT. The email included some of the responses they sent. As an example, here is their combined answer to the first two issues:

Comments to questions 1 and 2: Service animals should be defined as those that are 1) individually trained to do work or perform tasks for a person with a disability and 2) public access trained. Animals that do not meet both of these criteria should be designated as a separate and distinct category from service animals.

The Seeing Eye bred and trained all of my dogs (and trained me, too, for that matter) — and was at the forefront of making it possible for blind people to travel with trained guide dogs. So I take their, ahem, guidance, seriously. I think clearer rules about traveling with service animals could help eliminate some problems, so I’m going to follow their recommendations and send my own comments to the Department of Transportation. You can comment there, too — just make sure you submit comments by July 9, 2018 either on line, by fax, or by mail.

Beth and I exercise at the local Hilton Hotel, that one made famous during the riots at the 1968 Democratic Convention. It’s about our working-out speed—that is, no Crossfit zealots and not much spandex.

Our gym is nestled in this grand hotel.

Plus, we always get a little flavor from whatever conference is being held at the hotel, or from the big shows that are held at McCormick Place and use multiple hotels. The convention of school band directors for example, is easily discernible from, say, pharmaceutical sales people. Usually there’s a welcome sign, somewhere, that identifies the group(s) meeting there.

This week, though, like every year, one doesn’t need to go in to the hotel or visit McCormick place to know that the rollicking conclave of oncologists has hit town. Every year the American Society of Clinical Oncologists’ (ASCO) meeting draws 35,000-40,000 cancer doctors, drug company representatives, and other professionals to Chicago. And if you have any question about how much money there is in cancer, you wouldn’t if you simply took a walk in certain downtown neighborhoods. Like ours—Printers Row—where the two nearest bus stops are covered with giant ads for the likes of Keytruda, new gene therapies, and other cancer treatments.

One of the cancer-related ads plastered around downtown during the oncology conference.

I’m all for eradicating cancer but I wonder—

• Is everyone living with cancer able to get their normal treatment over these five days?
• Does anyone understand that, you know, while taking a pleasurable stroll down Dearborn Street, Michigan Avenue, or in River North, that one might not want to see a blown-up image of pancreatic cancer cells?
• And, for that matter, do the advertisers understand that people living with various types of cancer might not want to be reminded of that by the posters and billboards as they enter the subway?

I’m nostalgic enough to fondly remember the days when there were no drug ads. Not for failing erections, bad skin, wrinkles, IBS, cancer, not for anything. You went to the doctor to find out. But advertising to the doctor took longer to make sales than the industry liked. And the industry successfully pushed its agenda to advertise directly to consumers. From a Thrillist article:

Fast-forward to the 1980s: while Ronald Reagan was telling Americans to “Just Say No,” the feds cozied up to the pharmaceutical industry, and relaxed their legal restrictions. Direct-to-consumer marketing (DTCM), what you probably know as “drug commercials,” was first given the seal of approval in the US in 1985.

Even though pharmaceutical companies were legally allowed to advertise new drugs directly to consumers, the law still required a full list of side effects; this mandate meant DTCM ads were mostly restricted to print, then the only medium that could provide enough space to tell people they might get night sweats and night terrors and night cravings and night terror cravings.

Drug commercials as you know them really only began in 1997, when constraints were further loosened, and new meds began to feature in television commercials. For its part, the FDA notes that no federal law has ever outlawed drug ads, justifying its progressively lax regulation.

The ads work so well that Pharma now spends $4.5 billion a year on them. But there’s solid evidence that DTCM is more effective at making consumers aware of benefits than risks, and that they have a sort of power of suggestion—they manufacture illness.

And then there’s this: The United States has the highest prescription drug costs and highest health care costs in the world.

I’m sure it’s all coincidence.

I’m on the program!

The schedule for Northwestern University’s Summer Writers Conference just came out, and guess what? I’m on it! Here’s the workshop I’ll be leading there on Saturday morning, August 11:

Smelling is Believing: Writing Using Your Other Senses
with Beth Finke

Visual descriptions come easy to most writers, but when it comes to bringing readers into the story, the other senses are key. How can we give the forgotten four — taste, sound, smell and touch — their due? In this workshop we’ll read over short examples by noteworthy writers who describe events without the use of visuals, and then devote the rest of our time to writing — and sharing — in-class exercises to help us write like they do. Writers will leave with a personal essay to fine-tune at home and send for possible publication in journals, blogs, or magazines. This session is especially appropriate for new writers, but writers of all levels are encouraged to attend.

The 2018 conference runs from August 9 to the 11th in Chicago and features three days of workshops, panels, keynote speakers, networking events, and literary readings. Writers at all levels of experience are welcome, as are writers of all genres and backgrounds.

The full schedule and writer bios can be found on the conference website, And you can find the conference on Facebook, too. Register online and take advantage of early registration rates through Sunday, July 8. Smell you there!

Beth wrote about our visit to Perkins School for the Blind already—but before Perkins, there was New Hampshire. And after Perkins, there was a visit to Fenway Park (this baseball fan’s first). And after Fenway….

1960s kitsch at the JFK Museum.

A quick recap: It all started with a day and a night in Epping, New Hampshire that included a walk on the beach (yes, New Hampshire has 21 kilometers of shoreline that includes a great sandy beach), playing fetch with Whitney (who took her first saltwater dip), a lobster roll, some shrimp and hours of conversation and laughter with our friends Siobhan and Greg. Then, an overnight stay in an ancient riverside mill converted to apartments, and hours of conversation and laughter with our friends Mim and Kin.

In Boston we made a visit to the JFK Library and Presidential Museum. Beth had visited when she could still see and loved it. This time someone at Perkins arranged for Beth to have her own docent for a tour. I made my own way. The exhibits are terrific—including a set of 1960s era appliances, with black and white TV, aqua blue table radios, and that mid-century modern stuff that’s so popular. I can’t believe mid-century modern is a thing. For me it’s just the junk I grew up with.

It also reminded me of what a great orator JFK was. There was no dumbing down or talking down, the speeches were substantive and superbly written, and it was clear the speaker understood and believed in what he was saying.

And, well, the world was a mess. What new? I recommend visiting—the building itself, an I.M. Pei design, is worth it in itself.

Up close and personal with the Red Sox bullpen pitchers.

That night, we took in a Red Sox-Atlanta Braves game at Fenway Park on a picture perfect summerish evening. We sat right on top of the bullpen, and kids of all ages would come down between innings hoping for an autograph. One 20-something guy came down and kept yelling, “John, c’mon, John, even a nod?” He eventually remembered it was JoeKelly, not John Kelly, who was standing and watching the game. Joe gave him a nod, and the guy walked away in bliss.

It’s the second time I’ve sat near the bullpen (the other at White Sox park)—it’s a blast watching their warm-up rituals. The pop in the catcher’s mitt starts off muted, but then as the warm-up progresses, the volume rises with the velocity of the pitches. And at Fenway Friday night, we heard—for real—the bullpen phone ring.

As for Fenway, I’m glad I made it there. Not just to check it off my “parks visited” list—but just to see, in person, a place I’ve seen on TV most of my life. I still remember watching the Red Sox and Cardinals World Series in 1967. The Red Sox have done a great job using adjacent streets to open up the experience and make it easier than it otherwise would be to navigate. They also seemed to have done a pretty reasonable job (considering the vintage of the building) with accessible seating—something that anyone who uses or has pushed a wheelchair always scopes out, by instinct.

I got the requisite goose bumps walking in—but not because it was Fenway, per se. I get ‘em every time I walk into an MLB park for the first time. They each have their own character, the fans emit their own collective aura—and it’s always great to soak it all up. I’d rank Fenway up there, but PNC in Pittsburgh, AT&T in San Francisco, and Camden yards in Baltimore remain my favorites (after, of course, White Sox park—and the smell of grilled onions every time I walk in).

From there, it was a too-short visit to Alexandria, Virginia, where we… enjoyed hours of conversation and laughter with our friends Pick and Hank.

We sure are lucky.