I have been an assistance dog trainer for an organization for over eight
years. Part of my job is to provide ongoing follow up for our working
teams. Thank you for hearing and considering my comments and
suggestions.

Regarding the phrase "providing minimal protection:"

Our organization does train dogs to help people with seizure disorders
and other medical conditions. It is our policy to never allow our dogs
to display any type of behavior that might be interpreted as protective.
Just the fact that a person has a dog next to them is a deterrent to
foul play. It is very important that assistance dogs will allow
emergency personnel to approach and treat someone who is in a medical
crisis without interfering. Assistance dogs accompany their human
partners into ambulances and into hospital and other medical settings
where any type of protective behavior may be detrimental to the care
that the human partner needs to receive. Often, during or after a
medical crisis, the human partner may not be conscious, and the dog will
need to allow its partner to be approached and treated if necessary,
without showing signs of protectiveness. Within the dog training
community, the term protection is often used to mean a dog that has
received specific training to apprehend a person or persons from
interacting with its human partner. I think it would be beneficial to
state that the assistance dog will provide assistance to its human
partner prior to, during, and after the medical episode. I think the
term protection should be removed from consideration due to the great
possibility and liability that it be misinterpreted as permission to
teach aggressive behavior to assistance animals.

Regarding the elimination of certain species from the definition of
service animal:

Although I deal specifically with training assistance dogs, I do believe
that in certain cases, other species of animal can be beneficial to
allowing people with disabilities to maintain their independence. I
strongly believe that any animal taking on the role of an assistance
animal should be properly trained to meet standards of training, public
etiquette, and safety.

Regarding a size or weight limitation for assistance animals:

I do not think a size requirement should be placed on assistance
animals. There are many people working with assistance animals who
require a larger animal to assist them with daily tasks, such as balance
or support while walking.

Regarding restricting assistance animal access in hospitals and health
care facilities:

Over the past eight and a half years, I have heard many wonderful
stories from assistance dog partners who have had their dogs present in
birthing and delivery rooms. I feel this should be a personal decision
as to whether the individual person would like their assistance animal
present or not. Assistance animals are rarely if ever separated from
their human partners, and they each rely on each other. The assistance
animals become a part of their human partner. All of our clients find it
extremely important for their assistance dogs to be with them in pre-op
and then to be immediately reunited in recovery rooms. Normal stress and
anxiety levels associated with medical procedures and hospital stays can
be significantly reduced by the presence of their assistance dog. I
would ask that you please reconsider your request to restrict access in
hospitals and health care facilities.

Other issues I would like for you to consider:

In our industry, clients and assistance dog organizations use the term
assistance dog to include all working dogs that are helping to mitigate
a disability. Under that term, there are other more specific terms to
define how the dogs are helping the person. Guide dogs work with people
with visual impairments, hearing dogs work with people who are deaf or
hard of hearing, and service dogs work with people who have mobility
impairments or other medical conditions.

I am also concerned with the number of people who are trying to portray
family pets as assistance animals. There is a huge liability with having
people who have not been instructed as to proper assistance animal
public etiquette handling untrained animals in public settings. Our
organization takes great pride in preparing each of our assistance
animal teams for dealing with all sorts of public situations safely and
courteously. The reputation of assistance dogs begins to suffer when
businesses have poor experiences with people bringing in pets portrayed
as assistance animals who behave inappropriately. Businesses then begin
to deny access to legitimate assistance animal teams due to bad
experiences in the past. It becomes harder for legitimate assistance
animal teams when there are those out there who are misusing the law.
Please consider strong penalties for people who continue to misrepresent
their pets (who have not been task trained to mitigate a disability) as
assistance animals.

Thank you for taking the time to read my comments,

Deb Bauer

Trainer, assistance dogs