Recently, the DOJ proposed some rather alarming revisions to Titles II and III of the Americans With Disabilities Act. These changes include:
- A new definition for service animals;
- A significant weakening of the readily achievable barrier removal requirement for public accommodations;
- A significant reduction of elements required to be accessible in state and local government facilities;
- An exemption for all existing facilities from the new recreation and playground rules;
- And many others!
IAADP as an organization has already made an official comment regarding the new service animal definition, emphasizing that the following changes be made:
- Eliminate the phrase “providing minimal protection” from the definition of service animal;
- Eliminate the phrase “do work” from the definition because it is redundant and the example of work given in the NPRM, grounding, undermines the Department’s goal of maintaining a clear distinction between specially trained service animals and those animals whose mere presence can provide emotional support, companionship or therapeutic benefits.
- Limit the use of other species only to animals which can be trained to meet the same standards for behavior and training that assistance dogs must meet to qualify for public access.
- Avoid placing a size or weight limit on common domestic animals such as assistance dogs.
Further information from IAADP can be found here.
These changes in the ADA, especially the service animal definition, heavily impact the disabled community and I urge everyone to please take the time to add your comments to IAADP’s official comments and/or add to the draft comments from Disability Rights Education and Defense Fund (DREDF).
Please understand that even though these organizations (and others like them) have made comments that is imperative that DOJ receive your individual comments. We want to flood them with comments and we need the individual’s voice just as much as any large, faceless organization.