Issues Related to Accommodating Animals Traveling Through Airports (2015)

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10 chapter two CASE EXAMPLES In the course of studying the issues related to accommodating animals traveling through airports, the study team encountered the full range of types and sizes of airports, from small general aviation (GA) airports to very busy international hubs. Four case examples illustrate the range of accommodations for animals traveling with passengers or as cargo as well as the nature of the complex interactions that enable the accommodations to work. Roanoke–Blacksburg Regional Airport (ROA) is a typical non-hub primary airport that deals with service animals, emotional support animals, pets in excess baggage, pets in cargo, and other animals including research animals in cargo. Blue Grass Airport (LEX) in Lexington, Kentucky, has ultra-specialized facilities and procedures for one species—horses—of very high value animals shipped commercially. LEX is a small-hub air- port as far as its number of enplanements, but it is perhaps the most important airport in the world for the air transport of horses. Miami International Airport (MIA) is a large-hub airport that is also the second most important (in terms of dollar value) cargo airport in the United States. MIA and its stakeholders handle more species of animals in more types of transactions and interactions than any other U.S. airport. Only Los Angeles International Airport (LAX) comes close. Airports such as MIA show the multiple intri- cately choreographed interactions necessary for the safe transport of all categories of animals by air. The Heathrow Animal Reception Center (HARC) at London’s Heathrow International Airport (LHR) is both similar and very different from MIA. Both handle nearly the whole range of species and categories of animals traveling by air. The main difference is that at HARC, all the functions, procedures, and transactions of incoming animals are handled in a single, integrated facility. There is no separate case example for service animal relief areas (SARAs) and pet relief areas, as they are covered in detail in chapter four. There are three categories for animals transported in scheduled passenger air transportation: 1. “Unassigned in the cabin,” sometimes called “carry on.” Animals categorized as “unassigned in the cabin” are usually small pets that remain with the owner in the cabin for the duration of the flight, staying in carriers that fit under the seat in front of the passenger. 2. “Accompanied baggage,” also called “excess baggage” by the airlines. Animals categorized as “accompanied baggage” are pets traveling with passengers on the flight that are checked as baggage, remain in the custody of the air carrier for the duration of the flight, and are trans- ported in the cargo compartment of the aircraft. 3. “Live cargo shipments.” Animals categorized as “live cargo shipments” are animals that are not associated with passengers on the flight and are transported in the cargo compartment. “Accompanied baggage” and “live cargo shipments” may or may not be in different areas of the cargo hold of an aircraft, but the primary differences between these two categories are shipping procedures and cost to the passenger or shipper. CASE EXAMPLE 1—ROANOKE–BLACKSBURG REGIONAL AIRPORT This case example is based on an interview with Kari Dabrowski, Director of Operations and Main- tenance, on August 11, 2014, and on information provided in the airport’s website (www.roanoke airport.com).

11 ROA has approximately 50 flights a day and had 310,295 enplanements in 2013 (FAA 2014a). Its five airlines fly nonstop to eight destinations, six of which are major connecting points for domestic and international flights. Because ROA does not receive international arrivals, the FAA and TSA are the only federal agencies routinely operating in the airport. Table 2 summarizes the policies of ROA’s five airlines regarding the transport of companion animals. ROA has two airlines that accept pets traveling with passengers in aircraft cabins or as excess baggage or as cargo and three airlines that currently only allow pets to travel with passengers. In addition, ROA has cargo and freight service by FedEx Express and UPS; their policies are also included in Table 2. All five airlines accommodate service animals as required by the ADA and the Air Carriers Access Act (ACAA). ROA has two designated service animal and pet relief areas outside at each end of the front of the terminal. As of August 2014, ROA had no plans to construct or install a post-security relief area. Of the six connecting hubs reached by nonstop flights from ROA, four are served by the two airlines that accept animals as excess baggage and cargo. ROA does not have a separate cargo facil- ity that accepts animals. A person shipping an animal presents the animal in a crate approved by the International Air Transport Association (IATA) and the airline, with appropriate documentation at the passenger check-in counter. However, the process is complicated by the capabilities and limitations of the aircraft used by the various airlines. The two main variables are the presence/absence of adequate air flow in the baggage compartment, and whether the size of the compartment is adequate to handle animal crates. At ROA, for example, Delta uses Boeing 737 aircraft to Atlanta, while US Airways uses DeHavilland Dash-8 aircraft to Charlotte and Philadelphia. The 737 as configured for Delta can accommodate animals in TABLE 2 PET POLICIES OF AIRLINES AT ROANOKE–BLACKSBURG REGIONAL AIRPORT Airline Accepts Service Dogs Accepts Companion Animals in Cabin Accepts Pets as Excess Baggage Accepts Pets as Cargo Allegiant1 Yes Yes No No American2 Yes Yes No No Delta3 Yes Yes Yes Yes United4 Yes Yes Depends on aircraft Depends on aircraft US Airways5 Yes Yes No No FedEx Express N/A N/A N/A No UPS6 N/A N/A N/A Yes Source: Smith and McKinney data. N/A = Not applicable. 1Pets are accepted on flights in the passenger cabin. All pets must be in an FAA approved carrier that fits under the seat http://www.petswelcome.com/pet-air-travel/allegiant-air. 2In cabin pet allowed within and between the United States and Canada, Mexico, Central America, Colombia, and the Caribbean https://www.aa.com/i18n/travelInformation/specialAssistance/travelingWithPets.jsp?anchorLocation=DirectURL&title=pets. 3Dogs, cats, and household birds can travel with you in the cabin for a one-way fee*, collected at check in, to the following destinations (many) http://www.delta.com/content/www/en_US/traveling-with-us/special-travel-needs/pets/pet-travel- options.html#carry. 4Domesticated cats, small dogs, rabbits, and birds may travel accompanied in the aircraft cabin on most flights within the United States http://www.united.com/web/en-us/content/travel/animals/default.aspx. 5Accepts pets in cabin only http://www.usairways.com/en-US/traveltools/specialneeds/pets.html?re=1. 6UPS accepts live animals in IATA Live Animal Regulations (LAR) compliant crates or containers for shipment at an off-airport facility. Live animals must be shipped same-day priority.

12 cargo and excess baggage, while the Dash-8 cannot. Because airlines are constantly changing flight schedules and equipment, the airline websites, online reservation software, and live reservationists are the essential information source for the actual availability of excess baggage and cargo shipment of animals. It is unlikely that the airport will be able to provide precisely updated information. After an animal has been checked in, the crate is usually stored indoors until time to load it into the plane. The maximum distance that a crated animal is transported is 250 feet. For incoming animals, the process is reversed, and the crates are delivered at a door into the baggage area. ROA has never had a problem with an animal that got loose in the air operating area (AOA), terminal, or security area. No incident involving an injured or dead animal has ever been reported at ROA on the Airline Animal Incident Reports (AAIR) supplied to U.S.DOT. Passengers occasion- ally take pets out of crates in the terminal, and meeters and greeters also sometimes bring pets into the terminal. This violates airport policy that requires all animals in the terminal to be in crates except service dogs. Animals in containers must be removed for TSA screening of the container, but passen- gers usually control the animal with a collar and leash during these short periods out of the container. The crating policy is posted on the doors of all public entrances into the terminal. When these viola- tions occur, airport employees ask for the animal to be crated or to be removed from the terminal. The airport reports no issues with accommodating passengers or visitors accompanied by service dogs or emotional support animals. ROA keeps no data on the number of animals traveling through the airport. There is no regulatory requirement by any federal or state agency for an airport to collect such data. The airport’s website explains ADA accessibility options (www.roanokeairport.com/ada-accessibility- options) but does not describe or map the location of the service animal relief area. ROA’s website has links to the reservations and policies of the five passenger airlines. The ROA case exemplifies the complexities and need for information facing anyone who wishes to travel with an animal or ship an animal at a regional airport—indeed, at any airport in the United States dealing with domestic flights. The consumer is faced with lack of competition at regional airports if they need to ship an animal too large to fit under the seat. All airlines accept service dogs and almost all of them accept pets in the cabin. It is transporting putting a large dog or any animal unaccompanied by the owner in the cargo hold that is complex. CASE EXAMPLE 2—BLUE GRASS AIRPORT This case example is based on an interview with Amy Caudill, Director of Marketing and Public Rela- tions, and Scott Lanter, Director of Public Safety, on August 11, 2014, and information on the airport’s website (www.bluegrassairport.com). It is also based on an interview on September 10, 2014, with Mike Payne, Operations Manager, H. E. “Tex” Sutton Forwarding Company, LLC, also of Lexington, Kentucky. Lexington’s Blue Grass Airport (LEX) serves commercial airline passengers with 539,879 enplane- ments in 2013 (FAA 2014a) traveling on five airlines (the same five airlines as ROA, see Table 2 for their animal shipping policies) with nonstop flights to 15 cities. Of those 15, 10 are major connecting hub airports. There are approximately 80 flights per day. In addition to passenger traffic, LEX receives cargo and freight. The most significant type of cargo received at LEX is equine—race horses, show horses, polo ponies, event horses, horses for breeding, and horses for sale. In addition to passenger operations, LEX is the home base for numerous private aircraft. During special events such as horse races, horse shows and competitions, horse sales, and University of Kentucky athletic events, many more private aircraft fly into LEX and must be parked and serviced. LEX exemplifies how collaboration and communication among an airport and its stakeholders can protect the airport’s capabilities to handle competing lines of business. During both routine and peak equine shipping periods, specialized carriers work with the airport to site dedicated facilities

13 for horse operations in locations that minimize conflict with passenger and GA operations while optimizing the protection of the health and safety of the horses. The major horse transportation com- pany moves 3,500 to 4,500 horses per year through LEX. The company uses two customized leased Boeing 727 aircraft (see Figures 4 and 5) that are unloaded at a dedicated facility using special ramps directly into horse carrier trucks that leave the airport by a separate route from other traffic. Typically, a horse is landed, unloaded, put in a truck, and off the airport property within 45 minutes. Both the airport and Sutton Forwarding report that there have never been any problems involving horses dis- rupting airport operations. Both attribute this to communication, joint planning, professionalism, and attention to details, especially those involving the flow of horses through the airport. The only sug- gestion from the horse transport company would be for TSA to standardize its procedures between airports and within airports regarding the rules for escorting horse carrier trucks onto the airfield. The current situation sometimes creates delays that can increase the risk to horses. The airport’s role regarding horses is relatively limited. Primarily, it is the landlord of facilities. The horses go through USDA quarantine at Los Angeles, Miami, or Stewart (New York). The airport staff works to anticipate the needs for horse shipments and GA for special events and the eight major horse sales a year that are held in Lexington. The airport is currently doing the preliminary planning for the Breeders’ Cup in 2016, which will bring hundreds of horses and private planes, and tens of thousands of persons, to LEX. With regard to non-equine animals, LEX is unique among small U.S. airports in having post-security service animal/pet relief areas. These are grassed areas adjacent to ramps. When a passenger’s pet needs FIGURE 4 Customized 727 for horse transport at LEX (H. E. Tex Sutton photo). FIGURE 5 “Air Horse One” (H. E. Tex Sutton photo).

14 to use the area, an airport operations staff member escorts the owner and pet to the area. All gates are within a five-minute walk to a post-security relief area. The relief areas work well except during bad weather. In addition, LEX has several grassed relief areas outside the front of the terminal. LEX estimates that about 90 pets and service animals per month travel through the airport, and another 120 pets per month travel in cargo. About 45 non-horse livestock are shipped through the airport each month. The airport has had occasional issues with meeters and greeters trying to bring dogs into the terminal. Local health laws and airport policy require all pets to be in crates or carriers except for service dogs. Airport and airline employees politely inform the pet owners of the policy and ask them to leave the terminal. LEX puts special effort into training its employees on ADA issues and on animal issues. For exam- ple, LEX gives its paid part-time information center staff extensive orientation training that includes ADA, service animals, relief areas, and airport policies about animals. The airport’s website (www.bluegrassairport.com) includes an accessibility guide and a terminal map. The terminal map does not show the location of landside or airside (post-security) service animal relief areas. CASE EXAMPLE 3—MIAMI INTERNATIONAL AIRPORT This case example is based on a series of interviews with managers at Miami International Airport (MIA) and at companies and agencies that work with the air transportation of animals through MIA. The completed interviews were with Dan Agostino, Assistant Aviation Director for Operations; Ricardo Fernandez, Landside Operations Supervisor, Rene Casellas, Landside Operations Super visor, and Luis Arce, Acting Division Director Terminal Operations; Laura Moya, Senior Veterinary and Medical Officer, USDA–APHIS Animal Import Center, Miami; Adam Langer, Senior Quarantine Veterinary Medical Officer, and Julie Sinclair, Quarantine Veterinary Medical Officer, Quarantine and Border Health Services, Centers for Disease Control and Prevention (CDC); Nico Melendez, Public Information Officer, TSA; Rique Valdivieso, President and CEO, Animal Air Services, Miami; and Ben Daughtry, Vice President of Operations, Dynasty Marine Associates, Inc., Marathon, Florida. In addition, interviews were unsuccessfully sought from CBP, the U.S. Fish and Wildlife Service (USFWS), Worldwide Livestock Services Inc., and the Greater Miami Chamber of Commerce. Infor- mation concerning the Greater Miami Chamber of Commerce’s role in air cargo including animal shipments at MIA was obtained indirectly through other interviews. Melendez is located at Los Angeles International Airport, but was able to describe the same sorts of transactions and interactions that TSA experiences with animals at MIA. Among the 12 large-hub airports interviewed for this study, MIA is perhaps the most complex when it comes to the transportation of animals, with LAX in a very similar position. The main pur- pose of the MIA case example is to illustrate the nature of the transactions and interactions among the airport, airlines, animal handling and forwarding companies, and federal agencies involved with the domestic and international travel and shipment of animals. MIA serves commercial airline passengers with 19,422,275 enplanements in 2013 (FAA 2014a) traveling on 97 airlines, with nonstop flights to 144 cities in the United States, Canada, Mexico, the Caribbean, Central America, South America, Europe, and the Middle East. There are approximately 1,000 flights per day. Many passengers travel with pets or service dogs. In addition to passenger traffic, MIA is one of the world’s busiest cargo and freight airports, han- dling 6.85 billion pounds of cargo in 2013 (FAA 2014a). Twenty-nine (29) cargo carriers including FedEx Express and UPS serve MIA. Animals in all four AWA categories and all nine APHIS catego- ries figure prominently, both as imports and as exports.

15 Among U.S. airports in 2013, MIA ranked first in international freight, second in international pas- sengers, third in total freight, third in total cargo (freight plus mail), 16th in total number of operations, and 10th in total passengers. Among worldwide airports in 2013, MIA ranked ninth in international freight, 26th in international passengers, ninth in total freight, 10th in total cargo (freight plus mail), 24th in total number of operations, and 26th in total passengers (MIA n.d.). In short, MIA is a very busy airport with passenger operations and freight operations that are equally important. For passengers traveling with pets, the airlines at MIA offer the full range of possibilities within the limits of the individual airline’s policies—in the cabin in a pet carrier, as excess baggage, and as cargo. Passengers are responsible for getting the information they require to take their pets on flights and complying with it. The main interaction is between the passenger and the airline. The airport’s role is to provide and maintain service animal relief areas/pet relief areas. MIA has three outdoor animal relief areas, all with dual surfaces and waste disposal stations. Dual surfaces are important because service dogs are trained to relieve themselves on hard surfaces, whereas most pet dogs pre- fer grassed surfaces. Two of the areas are “whimsically themed ‘doggy parks’ ” (MIA 2014). There is abundant signage near the areas and in the terminal. Full information is available on the airport’s website and on maps throughout the terminal. As of November 2014, MIA did not have plans for post-security animal relief areas. One unusual animal-related service provided by MIA is the presence of a therapy dog, Casey, whom nervous travelers may pet. Casey and his handler circulate through the terminal, reassuring passengers and calming children (www.miami-airport.com/casey.asp). Casey has had obedience training and special training as a therapy dog. Other airports in this study that have therapy dog programs are LAX and SFO. People entering the terminals to meet and greet travelers sometimes bring pets. This violates a county ordinance as well as aviation rules and regulations, which state that only service animals on leashes and pets in containers that will be leaving by air or have just arrived by air are allowed in the terminal. The airport’s employees generally ignore this problem unless the pet creates a nuisance, which is a very rare occurrence. Airline and freight carrier cargo facilities for shipping animals as cargo are located on the airport property two to three miles from where planes are loaded. The biggest complication this presents is the need for temperature controls to offset Miami’s warm climate, but the shippers who accept ani- mals for transport have climate-controlled facilities and transport vehicles. In addition to the various on-airport facilities for animals, several animal handling and forwarding companies have off-airport facilities and pre-arranged access to the secure area of the airfield to load their animal cargo. As seen in the LEX case example, close coordination among the airport, airlines and freight carriers, agencies, and shippers normally makes for a smooth, efficient operation that protects the health and safety of the animals. One unique feature of the coordination and collaboration for animal cargo operations at MIA is the role played by the Cargo Network committee of the Greater Miami Chamber of Commerce. The network, which meets monthly, includes all the stakeholders involved in cargo shipments at MIA, including the airport itself, and Miami’s two seaports. When an issue arises that involves multiple stakeholders in animal transportation by air, the network provides a forum for discussion and the development of solutions. Everyone in Miami who was interviewed for this study commented on the effectiveness of this arrangement. The one difficulty noted in the animal handling company interviews is the complications sometimes created by the ironclad rules for the age, hard copy, and blue ink of veterinarians’ health certificates. The interplay of veterinarians’ office hours, flight schedules, and desired delivery dates on the receiv- ing parties’ end sometimes create delays and extra expense. The delays can threaten the health of the animals, particularly in the case of marine animals. The regulatory basis and details of the problematic requirements will be discussed in chapters three and four.

16 MIA reported that it has never had disruptions in its AOA or terminals from pets or other animals. If an airline has an animal get loose, it must report it to the airport. MIA will help the airline retrieve the animal. MIA trains all airport employees on Chapter 25 of the regulations of Miami–Dade Aviation Depart- ment (Miami–Dade Aviation Department 1995). Among many other things, Chapter 25 spells out the airport’s policies concerning ADA compliance, service animals, and pets in its terminals. The constellation of interactions among the stakeholders involved in the air transportation of ani- mals at MIA is summarized in Table 3. The table summarizes the stakeholders’ roles and notes how they differ for domestic and international travel. The single most important point made in all the Miami-related interviews is that there have been no major issues encountered with animals passing through MIA. This testifies to the benefits of coop- eration and joint planning among the stakeholders. Therefore, complexity in itself is not a problem. CASE EXAMPLE 4—HEATHROW ANIMAL RECEPTION CENTRE This case example is based on an interview with Susie Pritchard, Deputy Manager, on October 3, 2014, information on the centre’s website (www.cityoflondon.gov.uk/harc), and documents provided by HARC. LHR is the busiest airport in the world for international arrivals and the third busiest overall in terms of passengers. In 2013, LRH had approximately 36,184,000 enplanements in 2013 (ACI 2014). Its 82 passenger airlines serve 180 destinations in 85 countries; its 14 air cargo carriers handled 3.12 billion pounds of cargo in 2013 (www.heathrowairport.com/about-us). Comparison of the overall profiles of LHR and MIA shows that they are generally similar in the importance of international passenger travel and cargo. HARC is totally independent of LHR. The City of London Corporation owns and operates HARC under the United Kingdom’s Animal Health Act of 1981. HARC provides, either directly or through tenant agencies, the full range of services required to import an animal into the United Kingdom (U.K.). HARC and its partner agencies have as their goal providing one-stop service. Figures 6 and 7 show HARC’s facilities. HARC is the only post that can accept any species of animals. (Gatwick Airport has a privatized operation that can accept dogs, cats, and some other species. Edinburgh has a privatized operation that can only accept dogs and cats. Manchester receives many pets, fish, and reptiles. Stansted just east of London is the main port of entry for horses into the U.K., accounting for the low number of horses shipped through Heathrow.) The numbers of animals by categories that pass through HARC are shown in Table 1 in chapter one. Under the Pet Travel Scheme (PTS), with its standardized documents and requirements, it takes two hours to clear a pet arriving from a European Union (EU) country and about four hours to clear a non-EU arrival. A computerized database records information from air waybills and PTS documents. The Com- mon Veterinary Entry Document (CVED) gets entered for commercial shipments. A unique track- ing number is generated for each animal. The data system can generate summary reports by species, by airline, or by country of origin. HARC would like to see the database linked to the airport’s flight information, which would make for more efficient operations to meet flights. HARC is required as a statutory body not to make a profit. In general, the airlines pay charges for animals arriving under the PTS or commercial shipments. HARC only charges owners directly if special services (e.g., overnight boarding) are provided. Billing is connected to the database and bills are sent directly to the airline or its agent.

17 TABLE 3 STAKEHOLDER ROLES IN ANIMAL TRANSPORTATION AT MIA Type of Stakeholder Name of Stakeholder Role(s) for Domestic Flights Role(s) for Outgoing International Flights Role(s) for Incoming International Flights Airport MIA, including concessions and contractors Provide general information Serve as host to passengers and public Serve as landlord Provide SARAs Ensure ADA compliance in facilities Control pets in terminal Maintain security Airlines Any airline accepting animals for transport Provide specific information to passengers and shippers Inspect health certificate and rabies certificate Enforce IATA LAR Protect health & safety of animals Verify assistance dogs Resolve passenger and shipper complaints Contact foreign imports and customs to verify import permits are valid and receiver is expecting the animal; check health certificates and paperwork of animal when accepting it; check crate size, food and water containers, bedding, and all attachments to shipping containers Send attached paperwork to customs for clearing of animal; release animal when cleared by customs; assesses any damage to shipping container and animal if there is evident damage. Local Agencies Agencies Health Department Set and enforce animal vaccination requirements (e.g., rabies) Educate about and enforce local regulations on animals in buildings None. Veterinarians who are certified to issue health certificates work with APHIS. None Animal Control Deal with dead animals Remove strays from airport None None Federal FAA Set requirements for relief areas and access None None within airport facilities TSA Enforce security regulations Inspect crates and carriers Screen shipping container for explosives and contraband None USDA- APHIS Establish environmental standards for aircraft cargo holds that will carry animals Disseminate IATA LAR requirements Along with foreign governments, set health requirements and health certificate requirements; check and stamp verification of rabies vaccinations & other vaccinations, parasite treatment, titer tests etc. Along with CDC, ensure imported animals have required health certifications and testing and relay information to CBP (continued on next page)

18 Type of Stakeholder Name of Stakeholder Role(s) for Domestic Flights Role(s) for Outgoing International Flights Role(s) for Incoming International Flights Agencies Federal CBP None None Clear all imported animals, verifies recipient, verify all health testing requirements have been met; set paperwork and fees for commercial shipments and small owner/breeder imports Inspect for CITES violations USF&WS Establish standards for moving all fish and wildlife Enforce endangered species regulations CDC None unless zoonotic disease becomes epidemic Along with USDA- APHIS, set health, vaccination and testing requirements Along with USDA- APHIS, set health, vaccination and testing requirements for import; issue waivers on case- by-case basis if necessary Private Companies (examples) Air Animals Pet Movers Handle all procedures and documentation for pet owners or shippers Handle all procedures and documentation for pet owners or shippers Pick up paperwork for release by CBP; collect animal from airline Animal Air Transport farm animals and exhibit animals to and from airport Verify all required health certifications are in order Verify all required health certifications are in order and take such to CBP Load aircraft Handle documentation Dynasty Marine Transport marine animals to and from airport Load aircraft Handle documentation Worldwide Livestock Service Transport farm animals and exhibit animals to and from airport Load aircraft Handle documentation Verify all required health certifications are in order Verify all required health certifications are in order and take such to CBP Source: Smith and McKinney data. TABLE 3 (continued)

19 HARC leases an office to the U.K. Animal and Plants Health Agency (APHA) which issues CVEDs for unaccompanied pets and commercial shipments from outside the EU, combining the roles that APHIS and CDC have at U.S. airports of entry. The U.K. Border Force Convention on the Interna- tional Trade in Endangered Species (CITES) team is located at Heathrow near HARC and enforces the legislation related to endangered species. In addition to the one government agency (APHA), HARC houses one private company, a pet travel agency that handles customs clearance for British Airways passengers, accounting for 60%–70% of incoming companion animals at Heathrow. HARC has specially equipped vans with drivers who have been trained to the standards of the U.K. Civil Aviation Authority to drive safely in LHR’s air operating area. HARC uses these vans to meet and collect pets and animals directly from arriving flights except for British Airways and Virgin Atlantic, which have their own vans. HARC has extensive new employee and refresher training for its entire staff. Under the PTS regu- lating incoming companion animals, HARC provides the “Travellers Point of Entry” checks for pets, that is, physical and documentary checks, as well as providing for the animals’ welfare needs. Veteri- nary checks, where required for the purpose of issuing a CVED, are carried out by APHA; there are no vets employed by the city based at HARC. HARC has 26 kennels for dogs and 28 for cats, and their occupancy turns over several times a day. There is a separate building for fish. FIGURE 6 Heathrow Animal Reception Centre (HARC photo). FIGURE 7 HARC van meeting flight at LHR (HARC photo).

20 HARC has no responsibility for animal exports but carries out the statutory checking of exports under contract with the local authority. HARC does provide transit care when there is more than two or three hours between flights. HARC provides an individual service so that service dog users’ needs are met. This generates a fee that is payable by the British Airport Authority in the case of “recognised assistance animals,” or the owner in the case of “unrecognized” dogs. Emotional support animals are recognized by U.S. agencies and airlines as assistance dogs but are not so recognized by the U.K. or EU. There are some instances in which dogs are presented as “service dogs” but HARC does not believe them to have received any special training. This ruse is generally employed by people who do not wish to fly their pets in the hold of the aircraft, and is considered an abuse of the system. Recognized assistance dogs require pre-clearance and get special treatment when HARC meets the plane and traveler. For this service, HARC bills the airport authority. For U.S. carriers, the charge is £360 (about $525). If the arriving animal does not meet the U.K. or EU definition of “recognized assistance animal,” the animal is removed from the passenger and the passenger is charged the full fee directly. HARC receives verbal complaints and some verbal abuse towards HARC officers enforcing the legislation, usually from U.S. citizens who expect the U.K./EU policy to accept emotional support dogs without question or without documentation of training. HARC sometimes has to call for the airport doctor or security to help with the passenger. Part of the problem is that the U.K. has no legal definition of “service dog.” HARC would like to see a clear international definition of service dog and airline policies adjusted to match it. HARC prosecutes airlines that violate the IATA Live Animal Regulations (LAR). This results in 12 to 15 prosecutions per year. In January 2015, the Port Authority of New York and New Jersey announced that a dedicated full- service animal terminal was planned at John F. Kennedy International Airport (JFK). In the facility, several vendors will offer quarantine, boarding, veterinary, grooming, and training services for ani- mals being imported, exported, and in transit. The proposed terminal has been approved by APHIS. The facility is estimated to generate $108 million in revenues during the 30-year lease (FoxNews 2015). The proposed facility will offer more services than HARC.