Issues Related to Accommodating Animals Traveling Through Airports (2015)

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26 chapter four FINDINGS The 52 interviews, four case studies, review of documents provided by interviewees, and the literature review led to the identification of six significant issues related to accommodating animals traveling through airports. The team also identified several topics that are non-issues for all stakeholders, and even more issues that do not pertain to airports even though they are significant for other stakeholders. These issues support the findings from the case examples that the role played by airports is severely circumscribed by law, by regulation, by contracts with tenants, and by practice. This chapter presents six issues in detail: • Service animal relief areas/pet relief areas • Reducing stress on animals traveling through airports • Dealing with weather-related issues • Documentation of service dogs and emotional support animals • Communicating information about traveling with animals and shipping animals • Training needs. To the extent that an airport provides facilities used flexibly by two or more air carriers, for pas- sengers or for cargo, responsibility for some of the issues that pertain to airlines may be transferred to the airport and require the airport to make investments in facilities, equipment, environmental control, personnel, and training. However, the legal responsibility will still remain with the airline or freight carrier. The details of who does what and who pays in such common-use facilities are the subject of contractual agreements between the airport and the air carriers. Before beginning the interviews, it was thought that negative interactions between traveling pets and animals working for airports or other agencies would perhaps be an issue. For example, a pet on a leash might interfere with agricultural inspection dogs, police dogs, bomb dogs, or drug dogs working in the airport. However, in the interviews with the airports, airlines, and agencies, only one airport (Denver International) reported this as an issue, and a minor one. This appears to be the result of superior training of the working dogs that lets them and their handlers ignore or otherwise deal with distractions from other dogs in the terminal. Pet-working dog interference was found to be a non-issue. SERVICE ANIMAL RELIEF AREAS/PET RELIEF AREAS The ability to travel with a service animal, emotional support animal, or pet is important to a significant— and growing—segment of passengers. For airports, it is good business to serve these passengers and their animals. SARAs at airport terminals are the result of requirements set by the ADA, the ACAA, the Reha- bilitation Act of 1973, as amended (RA), and the Architectural Barriers Act of 1968, as amended (ABA); and FAA Advisory Circular 150/5360-14 (Access to Airports by Individuals with Disabili- ties). The AC assists airports in complying with the current laws and regulations governing individuals with disabilities by • Identifying the relevant statutes and regulations that impact upon airports; • Presenting in a single document the main features of each of the statutes and regulations;

27 • Providing legal citations to facilitate research; • Listing sources of assistance or additional information; and • Identifying the final rules for compliance, including SARAs (FAA 1999). AC 150/5360-14 applies to airports operated by public entities and those receiving federal finan- cial assistance, so it applies to all 23 U.S. airports in this study. The advisory circular does not explicitly require SARAs or specify their locations and characteristics. The AC requires the airport facilities to allow the use of service animals, which implies relief areas; but it does not address the issue of post-security SARAs or the issues of psychiatric service or emotional support animals. At the time of this study, AC 150/5360-14 is under review and is expected to be revised in 2015. The topics under discussion for revision are • Location and distance from airport entrances, boarding gates, and baggage claims, with impli- cations concerning post-security SARAs • Wayfinding and signage • Size and dimensions of SARAs • Surfaces in SARAs • Automatic and accessible doors • Garbage containers at entrance to SARAs, at a height accessible from wheelchairs • Assistance buttons, call buttons, or phones for emergency assistance • Use of non-toxic and low-odor cleaning solutions • Full enclosure of SARAs so that service dogs can be let free in area if needed • Protection of outdoor SARAs from elements (Bishop 2014; Miller 2014). Because of space constraints and capital, operating, and maintenance costs, all of these issues are difficult for many airports and the outcome of the advisory circular revision is uncertain. Particularly problematic is whether post-security SARAs will be required as the result of the adoption of the proposed 15-minute standard for the longest walk from a gate to a SARA. Any trip to a SARA that requires going out of security and back through security almost certainly would exceed the 15-minute walk advice. SARAs are the responsibility of the owner or operator of an airport terminal. Most often, this is the airport itself; however, at some airports, terminals are leased to or actually owned by airlines or independent terminal operating firms. Among the 23 U.S. airports in this study, DFW and MIA are examples of airports that lease terminals to an airline; JFK is an example of an airport where some terminals are owned by airlines and some are owned by independent terminal operating firms. LEX, ROA, SAN, SEA, and SFO are examples of airports that own and operate their own terminals. No matter who operates the terminal, potential complaints about SARAs, their location, their mainte- nance, and whether they are post-security generally go to the airport by default. According to interviewees, SARAs are increasingly viewed as a small but significant aspect of cus- tomer satisfaction. The airports with numerous SARAs, elaborate SARAs, and post-security SARAs all said that they viewed the capital, operating, and maintenance costs as an investment in customer satisfaction. Advisory requirements apply to facilities for service animals, not for pets. However, no airport in the study attempts to restrict use of its SARAs to service dogs and all allow free access to the relief areas for pets. Indeed, pets traveling through airports far outnumber service dogs. The discussion of documentation of service dogs later in this chapter relates to this, but no airport asks for documenta- tion or other proof that a service dog meets the legal criteria for a service animal as specified in the ADA and ACAA. For the rest of this section, “SARA” will be used to indicate a service animal relief area that also serves as a pet relief area. Existing Airport SARAs All 24 airports in this study comply with the current requirements for SARAs. Table 4 shows the number and locations of the SARAs at each airport.

28 TABLE 4 DESIGNATED SARAs AT THE 24 AIRPORTS IN STUDY Play” PIT 1 outside None 1 in airside terminal PSK Informal on grass out front None GA airport—None ROA 2 outside None None RSW 2 outside None None SAN 2 outside (1 between Terminals 1 and 2, 1 at Commuter Terminal) None 1 in Terminal 2 between Gates 46 & 47 (Figure 15) SEA 2 outdoor None 1 inside Concourse C (Figure 16) SFO 3 outdoor (1 at Terminal 1, 1 at Terminal 2, 1 at Terminal 3) None None Source: Smith and McKinney data. Airport Pre-Security/Landside Post-Security/Airside Adjacent to Terminal Elsewhere BOS 3 outside (1 at Terminal A, 2 at Terminal B, none at Terminals C & E) None None COT Informal on grass in front of terminal None GA airport—None DEN 1 outside terminal None None DFW 4 grassy areas outside Terminals A, B, C, & E None 1 inside Terminal D (Figure 12) DTW 3 outside (1 at McNamara Terminal, 2 at North Terminal) None 1 inside Concourse A DVT Informal on grass out front None Reliever airport—None GSO 2 outside terminal None None IAD 3 outside terminal None 2 inside concourses (Figure 13) JAN 1 outside terminal None None JFK 8 outside (1 at each terminal) None None LAX 4 outside (1 between Terminals 1 and 2, 1 between Terminals 5 and 6, 1 at end of Terminal 8, 1 at Tom Bradley International Terminal) (Figure 8) None None LEX “Several” grassy areas outside None 2 outside on apron MEM 1 grassy area outside None 2 inside Concourse B MIA 3 outside (Figure 9) None None MSP 2 outside (1 outside each terminal) None 1 inside Lindbergh Terminal (Figure 14) ORD 2 outside (1 at Terminal 1, 1 at Terminal 5) None None PHX 3 outside (“Pet Patch” at Terminal 2, “Paw Pad” at Terminal 3, “Bone Yard” at Terminal 4) (Cover, Figures 10 and 11) 2 at PHX Sky Train Stations: “East Economy Park & Bark” and “Park ‘n None

29 Figures 8–16 show the wide variety of designs, sizes, layouts, and amenities of existing SARAs at seven airports that participated in this study. Existing Post-Security (Airside) SARAs A search of the literature and follow-up discussions with airports with post-security SARAs and those considering installing them identified nine U.S. airports that as of November 2014 had post- security SARAs. The nine airports represent 1.7% of the 515 Part 139 airports in the United States. In 2013, the nine airports served approximately 14% of enplanements at all U.S. airports (FAA 2014a). Table 5 summarizes the characteristics of the post-security SARAs. Existing Pet Relief Area at a Cargo Facility That Receives Animals Port Columbus International Airport (CMH) in Ohio has a fenced animal relief area immediately adjacent to the facility that receives pets and other animals being shipped as cargo. One assistance dog agency interviewed urged that all cargo facilities that accept pets for shipping provide similar FIGURE 8 LAX’s outdoor SARA (LAWA photo). FIGURE 9 MIA’s outdoor SARA (MDAD photo).

30 FIGURE 11 PHX’s “Bone Yard” SARA outside Terminal 4 (PHX photo). FIGURE 10 PHX’s “Pet Patch” SARA outside Terminal 3 (PHX photo).

31 FIGURE 13 IAD’s post-security SARA in Concourse C (MWAA photo). FIGURE 12 DFW’s post-security SARA at Gate D18 (Kris Prettyman & Renea Porter photo).

32 FIGURE 15 SAN’s post-security SARA between gates 46 and 47 of Terminal 2 (SAN photo). FIGURE 14 MSP’s post-security SARA in Lindbergh Terminal (Phil Burke photo).

33 FIGURE 16 SEA’s post-security indoor SARA in Concourse C (Courtesy: Sea-Tac Airport/Port of Seattle). Airport Date Opened Location(s) Percent Airport’s Total Gates Served Walking Time from Farthest Gate LEX 2010 On apron outside concourse, requires escort 100% <15 min IAD 2010 Concourse A, Concourse C 100% <15 min SEA 2010 Central Marketplace 100 >15 min from N and S terminals that require train, then 7–10 min walk PIT 2011 Airside Terminal 100% <15 min MEM 2012 Near B, near Gate B11, and near Gate B27 100% <15 min MSP 2012 Lindbergh Terminal 92% <15 min DFW 2013 Terminal D Gate 18 (four more terminals scheduled by 2016) About 20% <15 min SAN 2013 Terminal 2 between Gates 46 & 47 100% <15 min DTW 2014 McNamara Terminal, Concourse A near Gate A34 82% 15 min Source: Smith and McKinney data. TABLE 5 EXISTING POST-SECURITY SARAs AT U.S. AIRPORTS AS OF NOVEMBER 2014

34 facilities so that animals can be relieved and exercised between rides in vehicles to reach the airport and being checked in as cargo. Figure 17 shows the pet relief area at the CMH cargo facility. Not only would a pet relief area at a cargo facility help prepare an animal for confinement dur- ing air transport, the human contact during exercise might help reduce the animal’s stress (Coppola et al. 2006). A Note on Costs In interviews, the survey team asked about the cost of building indoor SARAs. The reported range was $1,500 for fitting out an existing space (at DFW) to more than $400,000 for new construction in a concourse (two airports). The sample size was too small to compute a meaningful average. No data were collected on the cost of outdoor SARAs, primarily because they have typically been built as part of landscaping or pavement improvements. No data were collected on the operations and main- tenance (O&M) costs for SARAs. Interviewees explained that SARA construction and O&M costs typically come from the airports’ general O&M budgets or terminal O&M budgets, and expenditures on SARAs are not separately tracked. Characteristics of “Ideal” SARAs In addition to being required by laws and regulations, SARAs and pet relief areas are increasingly seen to promote the perception of good customer service. They are both a requirement and an amenity. Efforts such as improving the aesthetics and giving SARAs cute or memorable names appear to pay off in customer satisfaction. There was a consensus among interviewees that optimized SARAs will also be optimal for pets. Based on comments in the interviews with airports and service dog companies and on the presen- tation by Miller to the 2014 Service Animals Relief Areas Conference, a profile of desired character- istics of SARAs was compiled. Location There needs to be a SARA within a 15-minute walk of every gate and of the ticketing hall. This implies that post-security SARAs will eventually be necessary. Depending on an airport’s size and configura- tion, SARAs may be appropriate at special parking areas, mass transit stations, people-mover stations, and consolidated rental car facilities. Ideally, a SARA will be located near a family or companion restroom so that the animal’s owner can clean his or her hands. FIGURE 17 Pet relief area at CMH Cargo Facility (CCI photo).

35 These requirements suggest that the best time to plan for and design a SARA is when a new ter- minal or major renovation is being planned. “Best” here means minimizing installation cost and dis- ruptions to the terminal during installation. In the highly competitive environment among airports, terminal renovations are frequent and often very extensive, providing an opportunity to rethink the SARAs’ locations. Size The minimum suggested size is at least large enough for an assistance animal on a six-foot leash and its partner in a wheelchair. This implies something larger than 10 feet by 10 feet. Perimeter Control If outdoors, the SARA needs to be fenced with a gate. If indoors, the SARA needs a secure gate or door. Doors and Gates The doors or gates to enter a SARA may be automatic and need always to be accessible by the partners of service dogs. Surface The ideal is to have dual surfaces, one hard and one grass or grass-like, so that dogs can use the surface that they are most used to or trained to use. Service dogs are all trained to toilet on command on a hard surface, but this is not true of most pets. It is important that the surfaces be selected, designed, and installed for easy cleaning and for secure footing by service dogs’ partners and pet owners. “Amenities” Aside from the surfaces, which in many cases are quite attractive, the main type of amenity reported by the airports in the study is fire hydrant sculptures to provide a vertical surface for the male dogs that prefer them. The fire hydrants also help with the visual identification of the SARAs. Water and Drainage Many airports want there to be a water supply in the SARA to facilitate cleaning and maintenance, but generally do not desire the water to be available to pet owners. Drainage of SARAs needs to meet local building and health codes, which may require drainage containing animal wastes to be segregated from other floor drainage. Ventilation SARAs need good ventilation to clear pet odors, waste odors, and odors from cleaning supplies, and the ventilation needs to be to the exterior of the terminal, not into the terminal. Human Health A SARA will ideally have provision for hand sanitizer and paper towels. Signage inside the SARA needs to urge hand cleansing to control parasites such as roundworms. Locating the SARA adjacent or very near a family or companion restroom would serve the same purpose.

36 Maintenance Good maintenance requires that cleaning supplies (e.g., plastic bags and wipes) are readily avail- able at a height accessible from wheelchairs. SARAs also need a call button or telephone at a height accessible from a wheelchair to call for cleaning or maintenance. Automated cleaning and washing is possible with some SARA designs and surfaces. The post- security SARAs at IAD have such systems (Figure 18). Effective maintenance requires the SARAs’ being put on regular periodic inspection and cleaning schedules by airport maintenance employees or contracted maintenance or janitorial services. Use of non-toxic and low-odor cleaning solutions will avoid distracting dogs or preventing them from toileting. Signage Easily readable and understandable signs, preferably graphic or visual, are to be located throughout the terminal and outside as necessary to direct service dog partners and pet owners to the nearest SARA. Fully ADA-compliant signage and directional tools will ensure that sight-impaired travelers can find the SARAs. ACRP Report 52: Wayfinding and Signing Guidelines for Airport Terminals and Landside (Harding et al. 2012) provides excellent guidance for signs in general and ADA-compliant signage. Figures 19–23 show examples of effective signage for pet facilities at airports. Communication to Public In addition to signage, it is important that airport websites provide clear information about SARAs on airport websites with both maps and descriptions of locations. Websites with multiple naviga- tion paths to information about SARAs, accessibility, and traveling with pets are highly effective. Communications are discussed more fully later in this chapter. REDUCING STRESS ON ANIMALS TRAVELING THROUGH AIRPORTS The responsibility for communicating standards, rules, and regulations to those traveling with or ship- ping animals within, into, or out of the United States falls on the airlines and air cargo companies that are the actual transporters of animals. Table 2 summarizes the policies of five airlines concerning FIGURE 18 IAD’s self-cleaning SARA Design (MWAA slide).

37 FIGURE 19 Pawprints at SFO Leading to SARA (SFO photo). FIGURE 20 Graphic symbol on gate to outdoor SARA at SFO (SFO photo).

38 FIGURE 21 Fire hydrant in SFO SARA (SFO photo). FIGURE 22 Graphic symbol at entrance to SARA at SAN (SAN photo).

39 the acceptance of pets for transport. Analysis of the policies stated in all 11 airline websites (includ- ing those who declined to be interviewed) indicates that these five airlines cover the spectrum of services offered by various airlines. Although airports do not have a mandated role in this function, a loose animal could potentially create a situation compromising safety or security for airports, both in the terminal and on the AOA. Accordingly, it is crucial to examine stressors to animals and how to minimize both stress and stress-related animal escapes when transporting an animal by air, whether in the airline cabin, as checked excess baggage, or shipped as cargo. Since May 2005, all U.S. airlines that operate scheduled passenger flights and transport live ani- mals have been required by the U.S.DOT to file monthly Airline Animal Incident Reports (AAIR) on all pets that were lost or injured or that died during transport. The incident reports allow the consumer and regulatory bodies to track patterns of problems and assess animal safety. U.S.DOT publishes redacted versions of these reports on its website (U.S.DOT, 2012, 2013, 2014a,b). The U.S.DOT customer reports web page provides links to those reports, organized by the total number of reports filed by each carrier, the reports filed at U.S.DOT on a month-by-month basis, and the reports filed on a carrier-by-carrier basis. The DOT does not require reports to be filed for all incidents involving animals; the limitations of the scope of the regulation were discussed in an FAQ that the U.S.DOT issued shortly after it adopted the reporting regulations. Notably, reports currently are not required to be filed for incidents involving animals: • that are not kept as a pet in a family household in the United States; • that are carried on all-cargo or unscheduled flights (however, reports are required to be filed for incidents involving animals that are carried as cargo, as opposed to as checked baggage, on a scheduled passenger flight); or • that are carried on a flight operated by a foreign airline, even if the flight carries the code of a U.S. carrier (however, reports are required to be filed for incidents involving animals on a flight operated by a U.S. carrier between two foreign points, as well as on a flight operated by a U.S. carrier that carries the code of a foreign carrier) (Silversmith 2014). FIGURE 23 Sign at entrance to SARA at SEA (Courtesy: Sea-Tac Airport/Port of Seattle).

40 Further, in a letter to J.A. Silversmith, U.S.DOT elaborated that it also interprets the reporting requirements “not to apply to ‘escapes [which] last only a few minutes or a few hours’” (Silversmith 2014). On July 3, 2014, U.S.DOT revised the reporting requirements with the changes to take effect on January 1, 2015. Among notable changes: • Reporting obligations will now apply to all U.S. airlines that operate scheduled service with at least one aircraft with a design capacity of more than 60 seats. • Reporting obligations will now include, in addition to incidents involving pets, incidents involv- ing commercial shipments of cats and dogs. • Covered airlines will be required to file an end-of-year report even if they did not have any reportable incidents during the year, and to provide the annual total number of animals transported (which will provide context for the loss/injury/death reports) (U.S.DOT 2014; Silversmith 2014). While Silversmith examined the data from 2005 until November 2014, he focused on the most recent three years because airlines have increased training for all airline and contract personnel that are involved at any level with handling animals. This includes checking animals in, moving them around the terminal, loading and unloading animals on aircraft, and releasing animals to their owners or agents at the end of the flight. The focus on extensive airline and contract employee initial training and mandatory annual updated training appears to have reduced the number of animal injuries and deaths since 2005. This synthesis, looking at current practices and issues, reinforces the validity of limiting the analysis to the most recent three years. It is noted that incident reports cannot be viewed as a percentage of incidents relative to all animals flown because the total number of animals trans- ported by air on each carrier is not available. Pet injuries (Table 6) can be attributed to various causes, including a pet’s attempting to escape or pawing or biting at the crate, diseases (such as arthritis), or something as minor as a broken toenail. Consequently, injuries must be analyzed individually using the documentation accompanying each animal incident report filed. As an estimate of the incidence rates for 2013 of pet fatalities, the total number of deaths reported on AAIR in 2013 (Table 6C) was divided by the extrapolated national total based on the LEX esti- mates for 2013 and converted to a percentage. In 2013, there were 21 total reported deaths out of the estimated 1.97 million pets that traveled as checked baggage or in cargo, which gives an estimated incidence rate of 0.001% for death. If the total number of reports filed (40) is taken to indicate serious injury or death, then the estimated incidence rate for death or significant injury is 0.002%. No other data are available to test these estimates, but the incident rates appear to be very low. A stressed animal that escapes from its crate can cause safety issues for airports. Summary of airline incident reports from 2012 through 2014 (U.S.DOT 2012, 2013, 2014a,b) confirms that the number of improper crates (with unacceptable plastic latches and/or plastic crate doors) being accepted by airline personnel has decreased (Table 6B). The data also show that dogs chewing their way out of the crate or pulling/pushing the crate door in or out so that the animal can escape has decreased (Table 6A). Although the number of escapes has decreased, there is a high potential for escaped dogs to impact safety and security both in and out of the terminal. The AAIRs typically do not say whether the escape affected the operations of the airport. Moreover, as noted previously, airlines are not required to file reports on animals that escape and are recovered within a short span. Table 7 provides the number of incident reports for the percentage of dogs that chewed their way out of crates. Although the available data show an apparent decreasing trend, without data on the total number of dogs being shipped, it is impossible to determine the validity of the pattern. Two interviewees (SkyWest and “Airline X”) attributed the apparent trend to better training of employees and careful examination of each incident.

41 Airline 2012 (no. of incident reports filed) 2013 (no. of incident reports filed) 2014 (no. of incident reports filed) A. Dogs chewing out of or forcing their way out of airline crates (out of total incident reports filed) Alaska Airlines 5 (16) 4 (18) 2 (6) American Airlines 1 (7) 0 (3) 0 (2) Delta Airlines 7 (16) 1 (5) 0 (3) Hawaiian Airlines 0 (2) 1 (2) 0 (1) Horizon Airlines 0 (1) 0 (1) 0 (0) SkyWest No incidents No incidents 1 (1) United Airlines 0 (12) 1 (11) 0 (10) Total for Year 13 (54) 7 (40) 3 (23) B. Dogs escaping crate because of faulty crate (out of total incident reports filed) Alaska Airlines 2 (16) No incidents No incidents American Airlines 1 (7) No incidents No incidents Delta Airlines No incidents No incidents No incidents Hawaiian Airlines No incidents No incidents 1(1) Horizon Airlines No incidents No incidents No incidents SkyWest No incidents No incidents No incidents United Airlines No incidents No incidents No incidents Total for Year 3 (54) 0 (40) 0 (23) C. Total animal deaths (out of total incident reports filed) Note: Total animal deaths represents dogs, cats, rabbits, ferrets, birds, Guinea pigs Alaska Airlines 1 (16) 8 (18) 0 (6) American Airlines 6 (7) 2 (3) 2 (2) Delta Airlines 9 (16) 2 (5) 3 (3) Hawaiian Airlines 2 (2) 1 (2) 0 (1) Horizon Airlines 0 (1) 0 (1) 0 (0) SkyWest No incidents No incidents 0 (1) United Airlines 12 (12) 8 (11) 4(10) Total for Year 30 (54) 21 (40) 9 (23) D. Deaths of brachycephalic dog/cat as a percentage of total animal deaths Alaska Airlines 1 (1) 5 (8) 0(0) American Airlines 0 (6) 0 (2) 0 (2) Delta Airlines 1 (9) 1 (2) 1 (3) Hawaiian Airlines 2 (2) 1 (1) 0 (0) Horizon Airlines 0 (0) 0 (0) 0 (0) SkyWest No incidents No incidents 0 (0) United Airlines 2 (12) 1(8) 2 (4) Total for Year 6 (30) 8 (21) 3 (9) Source: Smith and McKinney data. TABLE 6 SUMMARY OF U.S.DOT AIRLINE ANIMAL INCIDENT REPORTS, 2012–NOVEMBER 2014

42 Some airlines refuse to transport brachycephalic dogs and cats either as checked baggage or as cargo. A few airlines (e.g., American, Delta, and United) will transport these animals only as cargo during a very narrow temperature range at all airports along the route, including connecting airports. However, more and more airlines, both in the United States and foreign countries, have either stopped transporting brachycephalic animals completely or transport them only under very spe- cific conditions. Most airlines will allow those animals to be transported as a carry-on in the cabin of the aircraft. Table 8 compares metal and plastic crates that meet IATA LAR and USDA-APHIS standards (IATA 2010; USDA 2014c). Figures 24 and 25 compare the appearance of approved designs of metal and plastic crates. Metal crates are clearly superior to plastic crates from the point of view of strength of material. However, the significantly greater cost of metal crates renders them unaffordable for most owners. Moreover, the additional weight of a metal crate alone may increase the cost of shipping an animal, since most airlines’ shipping prices are based on weight and cubic measurements. Consequently, airlines and owners must weigh the safety of the animal, the expense of purchase, shipping cost, and the potential consequences of an animal loose in the AOA or in an aircraft hold. Year Total Dogs That Chewed Their Way Out of Crates 2012 53 2013 40 2014 23 Source: Smith and McKinney data. TABLE 7 TOTAL DOGS THAT CHEWED THEIR WAY OUT OF CRATES Size: L x W x H Aluminum Crate Cost: Aluminum: Brand A Weight Size: L x W x H Plastic: Brand B Cost: Plastic Kennel 20" x 16" x 16" (size 100) $599.00 9 lb 21" x 16" x 15" $35.00 24" x 18" x 18" (size 200) $649.00 18 lb 24" x 16.3" x 14.8" 30" x 20 x 22 (size 300) $699.00 22 lb 28" x 20.5" x 21.5" $40.00–$80.00 32" x 20" x 24" $749.00 24 lb 32" x 22.5" x 24" $55.00– $110.00 36" x 22" x 28" (size 400) $849.00 32 lb 36" x 25" x 27" $65.00–$30.00 38" x 24" x 30" (size 500) $899.00 36 lb 40" x 27" x 30" $75.00– $150.00 40" x 26" x 30" $ 999.00 40 lb 42" x 28" x 32" (size 600) $1099.00 42 lb 46" x 30" x 45" (size 700) $1299.00 45 lb 48" x 32" x 35" $212.00– $280.00 Source: Smith and McKinney data. TABLE 8 COMPARISON OF METAL AND PLASTIC CRATES FOR ANIMAL TRANSPORT

43 FIGURE 25 IATA-approved plastic crate (IATA photo from Live Animal Regulations). FIGURE 24 IATA-approved metal crate (IATA photo from Live Animal Regulations).

44 Airlines can lessen the stress on animals by not requiring long pre-flight delivery times for animal check-in and by lessening layover times as much as possible. Airlines also provide quiet holding areas and personnel who are trained in handling and observing animals prior to flights, when the animal is unloaded from one flight, held for a time between flights, and uploaded to another flight (M.J. Rucker, interview, Nov. 30, 2014). There are also stress factors related to animals’ training; these are discussed later in this chapter. DEALING WITH WEATHER-RELATED ISSUES Weather-related issues complicate the shipping of pets because of the limited range of temperature an animal can safely withstand. The IATA’s LAR define safe shipping practices for anyone (pet ship- pers, commercial shippers, animal care professionals, zoos, ground handlers, freight forwarders, and airlines) involved in shipping live animals of thousands of species in air cargo. Domestic and inter- national airlines may have slightly different regulations for temperature allowances and restrictions for shipping animals either as checked baggage or as cargo. Generally, domestic airlines have a pet shipping embargo during the summer months. Airlines refuse shipment of animals in the cargo hold either as checked baggage or as cargo if the external ground temperature is predicted to be more than 85°F (29°C). Each domestic airline may have differ- ent minimum temperatures. Delta Airlines refuses shipment of pets in cargo when the temperature is below 10°F (-12°C). American Airlines refuses a pet when the minimum temperature is below 45°F (-7.2°C) during the animal’s transport but will make an exception if there is an acclimation letter from a licensed veterinarian. Each airline typically has its requirements clearly listed on its website; however, Alaska Airlines does not list an allowed temperature range. Most likely, the only way an airport would become involved in dealing with weather-related accommodations might be if the airport wished to develop a climate-controlled animal facility for lease to airlines and cargo carriers. Providing an airport-owned climate-controlled animal facility would be meaningless unless the airline tenant provides climate-controlled vans and unloads animals promptly (C. Lopez, interview, Sept. 17, 2014; “Airline X,” interview, Oct. 10, 2014; S. Pritchard, interview, Oct. 3, 2014). The transportation of a pet or other animal as checked baggage or in cargo may be disrupted when flights are cancelled or significantly delayed by weather or other causes that create an irregular opera- tions (IROPs) situation at an airport. ACRP Report 65 (Nash et al. 2012) is a guidebook to contin- gency planning by airports for irregular operations, but it does not deal with animals accompanying passengers, service dogs, or animals in cargo. Because the most frequent causes of IROPs are extreme weather events, typically winter storms, low temperatures are an issue for traveling animals. Airlines bear the responsibility for arranging any special accommodations in these circumstances, but the air- lines may request assistance from the airport. DOCUMENTATION OF SERVICE DOGS AND EMOTIONAL SUPPORT ANIMALS In September 2010, the U.S. Department of Justice revised and clarified the definition of service ani- mals as specified in the ADA for Title II (State and Local Government Services) and Title III (Public Accommodations and Commercial Facilities) in the Federal Register. Since March 15, 2011, only dogs (not other species) have been recognized as service animals. The definition of a service animal is a dog that is individually trained to do work or perform tasks for a person with a disability. Generally, Title II and Title III entities must permit service animals to accompany people with disabilities in all areas where members of the public are allowed to go (U.S. Department of Justice 2010). The Department of Justice memo states: Examples of such work or tasks include guiding people who are blind, alerting people who are deaf, pulling a wheelchair, alerting and protecting a person who is having a seizure, reminding a person with mental illness to

45 take prescribed medications, calming a person with Post Traumatic Stress Disorder (PTSD) during an anxiety attack, or performing other duties. The work or task a dog has been trained to provide must be directly related to the person’s disability. Dogs whose sole function is to provide comfort or emotional support do not qualify as service animals under the ADA. In addition to Title III regulations, airports and airlines are subject to the ACAA, which defines service animals much more broadly to include emotional support animals or “comfort animals” that do not qualify as service animals under Title III regulations (Brennan n.d.). These animals do not have special training to perform tasks as covered in the ADA to assist those with disabilities. Con- sequently, airports must accommodate a larger number of service dogs and emotional support dogs traveling through airports. Because of the broad ADA definition of service animals and the more encompassing definition the ACAA uses for animals allowed to accompany persons with disabilities, it is increasingly dif- ficult to exclude an animal or to determine whether or not that animal is in reality a service animal, a trained animal, or one that a passenger simply wishes to take on the airline at no charge. There are no clear-cut requirements for training and no official registry of service animals in the United States. The passenger cannot be asked about his or her disability, show medical documentation, provide a special identification card or training documentation for the dog, or ask that the dog demonstrate its ability to perform the work or task. On the other hand, if a person claims an animal is an emotional support animal, he or she may be asked to show a letter on letterhead stationery from a mental health professional. When such a request is made, it is normally made by an airline at the time when the passenger is asked to pay a fee for taking the animal in the cabin. In the interviews with airports and airlines, it was found that most were aware of the allowed questions but uncomfortable about having to use them. However, as discussed in chapter three, the ADA has established behavioral guidelines for the ser- vice animal, which must be under control by means of harness, leash, or tether, unless these devices interfere with the service animal’s work or the individual’s disability prevents using these devices. In that case, the individual must maintain control of the animal through voice, signal, or other effective controls. A dog that barks, is threatening, is not housebroken, or in any other way is disruptive by vir- tue of improper or uncontrolled behavior can be barred from entering or remaining in an airport or on an aircraft. Appendix A summarizes unacceptable behaviors by services dogs and by any other type of animal in an airport. Both airports and airlines reported instances when they used misbehavior of animals to require the owners to remove them. In the case where a service dog is removed from an airport, the airport must under ADA rules provide other accommodation to allow the individual with a disability full access to services in the airport. Some interpretations of the ADA definition of service animal, combined with the ACAA’s far- reaching definition, have resulted in an increasing number of passengers bringing animals with them into airports and onto flights at no charge (Jackson 2014). This has created a backlash among both non-disabled passengers and those with disabilities, as more passengers appear to be passing their pets off as service and emotional support animals (Kawczynska 2013). Publications from the New York Times, Palm Beach Post, The New Yorker (2014), and Yahoo, and social media discussions have vaulted this problem of “service dog fraud” into the limelight. The California State Senate held hear- ings on the issue. The ease with which “credentials” can be obtained in the United States for service dogs has been abundantly documented in the literature. Organizations and business enterprises have sprung up on the Internet whereby credentials and identification cards and animal gear can be purchased with no proof of need on the part of the person or individual training for the animal. Obtaining documentation for an emotional support animal is not as difficult as it may seem. A quick Google search leads to the (firm’s name removed) Service Animal Registry, which provides links and information about how to have a pet classified as an emotional support animal. For $64.95, plus shipping, this firm will add the pet to its online registry and send two ID cards, two leash clips, and a certificate of registry with an embossed seal.

46 If a pet owner doesn’t have a psychiatrist willing to write a letter, that can be obtained online for a fee, too (Moran 2014). While U.S. airports’ hands are tied in identifying and differentiating critically necessary service and emotional support dogs from what is being termed “pseudo” and “fraudulent” service dogs, the United Kingdom handles this quite differently (S. Pritchard, interview, Oct. 3, 2014). “Service dog fraud” is considered to be an increasing problem at the Heathrow Animal Reception Centre (HARC). HARC defines “recognized assistance dogs” as dogs that meet the ADI training standards (ADI 2014c). Service dogs flying into and out of Heathrow Airport are considered legitimate if, and only if, those dogs are registered with a legitimate service dog registry. Service dogs, like all other dogs, must comply with all EU health requirements, which can be different from country to country. HARC and EU policies also stop owners of so-called pseudo service animals from entering the EU free of charge (S. Pritchard, interview, Oct. 3, 2014). It is clear that the broad definition of legitimate service and emotional support animals and the lack of clear-cut training, registration, and positive individual identification (e.g., implanted microchips) of such animals will continue to cause increasing problems as more of these dogs travel through airports. Using implanted microchips to identify qualifying animals will require airports and airlines to purchase universal microchip scanners, the cost can potentially be recovered by weeding out free flights for pseudo service dogs. It will generate goodwill with the public and with those who depend on service dogs, and will result in fewer incidents of misbehavior and disruption in the airport and on flights. This is the system used at HARC and throughout the EU (S. Pritchard, interview, Oct. 3, 2014). Of the 20 U.S. airports in the initial sample, only two reported experiencing a significant issue with pseudo service dogs, and this happened when the airports attempted to enforce “service animals only” policies in their terminals. Unlike the airports, all interviewed airlines said it is a major problem. One federal agency noted that false claims of service dog or emotional support animal status become an issue when fees are charged for certifying veterinarian health certificates (L. Moya, interview, Sept. 16, 2014). When asked about the desirability of a national registry for service dogs, interviewees gave a wide range of responses. Most airports had no opinion except the two that had had an issue. The airlines would like to have clear documentation of an animal’s special status if that status would exempt the owner from fees. The service dog companies all said they would welcome a national registry but noted that executing such a program had been problematic and would be difficult. The primary source of difficulty cited was the question of how to include or exclude emotional support animals. Associations of service dog and assistance dog users and partners were widely split in their opin- ions. Although most supported a registry, one emphatically objected to any additional restrictions or requirements. The basis for this objection is that the “individual training to a set standard” aspect of a registry would disadvantage, perhaps greatly disadvantage, assistance dog partners while addressing a problem (fraudulent service dogs) that is very small compared with the actual needs of people with disabilities (Joan Froling/IAADP, interview, Sept. 27, 2014). The issue of what constitutes a service dog or an emotional support animal has been complicated by the expansion of the tasks performed and the range of disabilities for which service dogs provide a service. Beyond providing the traditional sight, hearing, and mobility assistance, service dogs are now helping persons with seizures, diabetes, autism, and PTSD. A reference that may be helpful to airports, airlines, and any party concerned with this increasing issue is the chapter, “Assistance Animals: Their Evolving Role in Psychiatric Service Applications” by Tedeschi et al. (2010) in the Handbook on Animal-Assisted Therapy: Theoretical Foundations and Guidelines for Practice (3rd edition). The authors discuss the conflicts involved when pets are misrepresented to take advantage of rights established by ADA (pp. 422–423). They explain how emotional support animals are different from psychiatric service animals (p. 428), and discuss service animals, registered/certified therapy animals, and emotional support/companion animals (Table 20.1, p. 430). This helpful reference does not supplant the ADA and ACAA and their related regulations, but it can help operators and planners in the aviation industry understand the issues that sometimes underlie conflict.

47 COMMUNICATING INFORMATION ABOUT TRAVELING WITH ANIMALS AND SHIPPING ANIMALS This section focuses primarily on how airports communicate with the public on issues related to ani- mals traveling through airports or entering terminals with visitors. Communications by other stake- holders, including airlines, agencies, and animal handling and forwarding companies, are discussed as they can be linked to airport communications strategies and methods. Once again, it is essential to note that the responsibility for knowing the procedures for animals at airports lies with passengers traveling with animals, individuals shipping animals, meeters and greeters entering the terminal, and the airlines. Airports have a limited required role in communica- tions about accommodations for service animals, but airports can greatly assist the public by making accurate information concerning pets and other animals readily accessible. The airports reported that good communications regarding pets appear to create a greater perception of being their being customer-friendly and possibly lessen complaints and crises dealing with animals. To various degrees, all 24 U.S. airports in the study attempt to inform the public. Airports reported at least seven basic methods for communicating with the public: websites; social media; press releases; signage in terminals (including maps, signs on public entrances, and localized communications through social media); automated dial-in telephone information systems; one-on-one communication by airport employees, information centers, airport ambassadors, or other volunteers, whether in person, by telephone or by e-mail; and targeted outreach to specific audiences. In the interviews with the 20 U.S. airports in the initial work plan, it was found that none used fewer than two methods, and one airport used all nine methods. Both airports and their customers seem likely to continue to depend most heavily on websites for information purposes concerning animals. Furthermore, the increasing dependence on smart phones will probably mean that social media and localized broadcast info over phones will make those methods ever more important to airport customers with pets. However, interviewees responded that signage at airports probably will remain the single most important source of actionable information by customers with pets and service animals. Websites Every airport interviewed had a website. However, the amount and types of information about trav- eling with pets and animals varied widely, as did the ease of navigation to find the information that was in each website. Analysis of the websites of the initial 20 airports, plus the three that were added (Detroit Metropolitan International, Memphis International, and Pittsburgh International) because they have post-security SARAs, revealed a number of features that any airport may wish to consider: • Multiple pathways for navigation of the website starting from customer’s need of information, such as: – Service animals, which will typically be addressed under accessibility or ADA compliance – Pets traveling in plane cabins – Pets traveling in excess baggage – Pets being shipped as cargo – Other species being shipped as cargo – Pets accompanying meeters and greeters • Search engine capabilities that will find any of those six types of need • Links to airlines’ websites to level of detailed pages for – Pet transportation policies and procedures – Animals in cargo policies and procedures • Links to key federal agencies’ websites. This is problematic, as airports may wish to keep the customer procedural inquiries directed through the airlines to the agencies. • Description of SARAs – Location – Facilities – Photographs of SARAs

48 • Maps—static or interactive, ideally both—that clearly show – the location of all SARAs – the location of the facility for receiving animals to be shipped as cargo, if that facility is separate from the terminal • Written directions for reaching the animal-related places shown on the maps • For large-hub connecting airports, information concerning – Procedures for getting to SARAs between flights – Estimates of time to make connections and using a SARA, especially if exiting and entering security screening is involved • Requirements for animals in the terminals, such as – Service animals requiring leashes or harnesses – Pets remaining in carriers or crates unless local regulations allow them on leashes – Policies on owners’ control of animals and consequences of bad behavior • Contact information – For requesting assistance – For complaints and compliments – For medical emergencies • Information on the airport’s therapy dog program, if any • Information on pet-related concessions (spas, boarding, grooming, etc.) • Images of success stories involving animals traveling through the airports • Surveys of customer satisfaction with the airports’ accommodations for animals • Adaptive technology in website to allow sight-impaired customers to obtain the information about accommodations for service dogs. FAQs (Frequently Asked Questions) are used by about one-third of the airports in the study on their websites, but only two airports had pet-related FAQs. Social Media Use of social media by an airport to put out information of the types just described for websites appears unlikely, based on the interviews. There are serious limits on the ability of social media to put out sustained information; by nature, social media are intended to be immediate and ephemeral in their impact. However, social media can be very powerful used in the other direction, that is, by customers to communicate with an airport or to complain about the airport. Because passengers and meeters and greeters often have the mistaken view that the airports have the primary responsibility for the safe handling of their pets, fast-moving negative messages on the social media can hurt an airport’s reputation. For this reason, airports may wish to monitor social media and develop strate- gies for rapid response to negative posts. It is possible that social media will develop into near-real-time problem-solving systems that will help customers (e.g., pet owners) obtain help from other customers, previous customers, airports, or other stakeholders. DFW’s Public Affairs Department is already gaining benefits from real-time responses through such a system (M. Crear, personal communication, Dec. 6, 2014). Airports may also consider using separate social media accounts to publicize their services for pets. Although it is not an airport, HARC has a Facebook page (City of London 2014). Press Releases Precise, informative press releases are essential for airports, both for dealing with animal-related cri- ses and for telling the world about success stories and innovative solutions. Airports have recognized that excellent accommodation of animals is increasingly becoming seen as an indicator of superior customer service in general. As far back as 1993, international airports had begun to view superior accommodations for animals and their handlers as a competitive advantage (Theurmer 1993). These airports have used press releases to support this trend.

49 Signage All types of signs, both outside and inside terminals, have long been the focus of great attention by airports and their stakeholders, with a goal of improving the experience of customers. These consid- erations and best practices for signs and wayfinding were summarized in ACRP Report 52 (Harding et al. 2012). Directional signs to SARAs and other special facilities for animals are needed, and self-evident graphic symbols can be very effective, especially in a port-of-entry airport where many customers do not speak English. The most effective signage for SARAs can be the design of the SARA itself. Many airports use full-size or small-scale fire hydrants, both of which symbolize dog toileting. Other design cues help customers recognize SARAs quickly. The figures earlier in this chapter dealing with SARAs illustrate the power of such imagery, as do Figures 24–25 in this section. Every airport in the study uses maps in its terminals and on its website. Not all of them mark the SARAs clearly on the map, but most do. The most effective practice appears to be to use a distinctive, clearly visible icon to mark the location of SARAs on the maps and to use the same icon or imagery on signs pointing to and identifying the SARAs. One special type of sign outside terminals is one on the public entrance doors that spell out the airport’s policy or local ordinances concerning service animals and leash or crate requirements for all other animals (Figures 26 and 27). In the interviews, some airports reported that such signs are fre- quently ignored by both passengers and meeters and greeters, but the signs give notice that the airport may choose to enforce the rule. Similar concerns guide the inside signage with the added complications of greater competition for attention and less space for pet-related and SARA-related signage. Most of the airports interviewed said they use a combination of terminal maps with signs at the entrance for indoor SARAs (usually post-security SARAs). Figures 22 and 23 show the signs marking the entrance to the post-security SARAs at SAN and SEA. FIGURE 26 ROA arrivals entrance (Kari Dabrowski photo).

50 Automated Telephone Information Systems Many businesses, including some airports, use automated telephone information systems, but the relatively low frequency of pet-related questions means that they would probably be very low prior- ity in the menus given to callers. No interviewee cited this method as particularly effective. One-on-One Information One-on-one information includes telephone, e-mail, and face-to-face questions and answers. Of these, face-to-face inquiries to information centers, information booths, kiosks, airport ambassadors, airport police, and perhaps contractors such as cart drivers and wheelchair assistants are the most common. Many of the airports include training on ADA, SARAs, and pet rules, safety, and health in their orientation training. A few airports use contract and lease terms to require concessionaires and contractors to have similar training. Targeted Outreach By targeted outreach is meant special events held by an airport to educate a particular segment of the public or customers about the airport. With regards to animals traveling through airports, the team found two examples of targeted outreach: • All of the service dog training companies have arrangements with airports for orientation visits to the airports as part of the individual training that distinguishes a service dog from emotional support dogs and pets. About half the airports in the study have hosted such training. • Several of the airports hold regular orientation sessions for autistic children to accustom them to the noises, lights, and distractions of a busy terminal. Non-verbal autistic children increasingly are tethered to specially trained service dogs to prevent the children from getting lost (Solomon 2010; T. Grandin, interview, June 20, 2014). Boston Logan International Airport (BOS) has taken an alternative approach. In 2008, BOS real- ized that 1,500 to 2,000 pets passed through the airport every month. Upon analysis, BOS identi- FIGURE 27 RSW arrivals entrance (Lisa LeBlanc-Hutchins photo).

51 fied pets as customers of the airport—“pets” to BOS included service, companion, show, and research animals—and sought better ways of accommodating them. A small number of pet medi- cal emergencies occurred in which the airport ended up as the final recourse for relief. One ani- mal escaped its container onto the AOA and caused flight delays. Massport (the airport’s parent agency) partnered with the Massachusetts Emergency Management Agency, the Animal Rescue League of Boston, and the Veterinary Emergency and Specialty Center of New England to per- form a comprehensive needs assessment. The partnership also identified emergency medical equipment needs such as dog muzzles, gloves, nets, leashes, soft stretchers, catch poles, oxygen cones, and vet wraps as well as training needs. BOS arranged to have a pet ambulance assigned to the airport and made agreements with two receiving hospitals in case transport is required. More than 250 members of the airport community received the specialized training. PetPorts were opened in each terminal. A separate data category was established for fire department run reports for animal responses (Massport 2014). A PetPort is a clearly marked spot in each terminal with posted instructions (Figure 28), an emer- gency phone, a location statement, emergency supplies such as a slip leash, and “Safe Travel Tips” for pets. Terminal maps label the location of the PetPorts as well as SARAs. BOS also uses a highly visible physical indicator to emphasize its overall message about safe pet travel and encourages pet owners with problems to initiate action on their own while promptly summoning appropriate help from the Massport Fire Rescue department. In the four years since FIGURE 28 Sign identifying a PetPort in Boston Logan’s Terminal A (Massport photo).

52 reviewing and revising its entire program, including the PetPorts, BOS has had no escapes and only four pet medical emergencies requiring action by the airport. Thus, BOS sees its PetPorts as improving airport efficiency and enhancing customer service. TRAINING Training was a recurrent theme throughout the interviews and in the literature. As seen previously in this chapter, protecting the health and safety of animals requires proper handling, the issues of ADA and ACAA compliance are sometimes intricate, and the consequences of failure can be large. For these reasons, every person and organization interviewed stressed the importance of initial and refresher training. Training at Airports Most airports reported including specific training on ADA compliance and on animals in terminals as part of orientation training. Several airports that use volunteers (often called “airport ambassadors”) reported including them in the same training as airport employees, and two airports reported giving their ambassadors even more training, as the ambassadors were the likeliest persons to receive ques- tions from passengers and meeters and greeters with service dogs or pets. While HARC is not an airport, its training program, and how training requirements are incor- porated into job descriptions, are illustrative of the customer service-oriented airports in this study (HARC 2012, 2014). Training at Airlines Five airlines provided information for this study. Two, Southwest and JetBlue, explained that they do not transport animals in their planes except for service dogs traveling in cabins. The other three airlines (Lufthansa, SkyWest, and “Airline X”) described their training procedures and policies. They use extensive in-person and online training of all employees that have duties that bring them in contact with animals. The training is given to new employees and as annual refresher training for current employees. Emphasis is placed on IATA’s Live Animals Regulations (LAR), on crate require- ments including water and food, and on required health certificates and other documentation. Some airlines use specialized reservationists for passengers traveling with pets or shipping pets, and others give regular reservationists software support to deal with the details of traveling with pets. In either case, the airline provides specialized training for the reservationist. Because requirements for inter- national travel of pets varies from country to country and changes often, the training of call center reservationists is critical. Such training needs to include referral of pet owners to APHIS for current country-specific requirements. SkyWest and “Airline X” have comprehensive training programs for reservationists, counter agents, gate agents, cargo handlers, van drivers, and customer service personnel. Lufthansa has a similar program. Training of Passengers and Shippers Since the primary responsibility for knowing and meeting the requirements for the safe transport of animals lies with the owner of the animal, it is important that reliable information is readily avail- able so that passengers can educate themselves. The websites of all 11 airlines examined in this study clearly state airlines’ policies regarding the transport of pets in cabins, as excess baggage, and as cargo. The airlines that accept pets as excess baggage and/or cargo have trained their reservationists to provide information to customers. There are a number of organizations and sponsored websites that provide information for travel- ing with pets, and these sites are easy to find with typical search engines. One problem with some such sites is that they often out of date, not having been updated to reflect changing airline and gov-

53 ernment agency policies. The associations that serve disabled persons and persons using emotional support dogs appear to put great effort into keeping their websites up to date and user-friendly. Training of the Traveling Animals Perhaps the most urgent type of training, yet the most overlooked, is the training of pets and other ani- mals to habituate them to crates or carriers. Such training can reduce stress and risk to pets (Grandin 1997). It can be very stressful for the pet if the first time it encounters a crate or carrier or experiences separation from its owner is when it is being crated to go to the airport. Many pets are not acclimated to the noise outside of their homes or are not used to being confined for extended periods. Owners bear full responsibility to ensure that their pets are well trained, are comfortable in a shipping container (crate), are at ease staying in that crate for as many hours as a flight lasts, are capable of traveling in a noisy environment, and are relaxed about their crate being moved and accepting when handled by multiple strangers. A program of gradual acclimatization to the crate, special water container, and separation will help the animal stay calm and safe during air travel. This is not a process that can be accomplished at the last minute but instead requires weeks of training for an older puppy or adult dog (M.J. Rucker, interview, Nov. 30, 2014). Training includes exposing a dog to unfamiliar noises, such as the owner’s driving a vehicle with the crated pet through a car wash (W. Woolf, interview, Jan. 5, 2015). Owners must also recognize that some animals are simply not temperamentally able to withstand the stress of air transport, the stress of being crated and moved, or are by nature, noise sensitive or suffer from separation anxiety through no fault of their own or their owners (M.J. Rucker, interview, Nov. 30, 2014). Service animals are trained to maintain discipline during travel. The service animal compa- nies use one or more sessions in airports or simulated airport environments to train their animals (J. Dugan, interview, Jan. 5, 2015). A Possible Enhancement by Airports: Animal Emergency Contingency Planning Several airports said that when something goes wrong with a pet traveling through the airport, either the customer or the airline may dump the problem on the airport. Although it is nowhere required in the laws, regulations, or advisory circulars, an airport may choose to develop an animal emer- gency contingency plan or pet emergency contingency plan. BOS developed such a plan in 2008 and has found it to be effective in controlling situations and at building customer satisfaction. (See the description of BOS’s PetPort program earlier in this chapter.) If an airport chooses to develop an animal emergency contingency plan, the most effective approach is to involve all the stakeholders, including airlines, law enforcement, and local partners such as animal control, veterinarians, pet ambulance companies, animal hospitals, and local boarding kennels. The plan can also include guidelines for internal and external communication concern- ing the incident and its resolution. An animal emergency plan can include arrangements for veterinary services (usually through the airport’s police who use K-9 dogs), animal transport, flight delays, weather extremes, and IROPs. An airport animal emergency plan can include procedures for handling animal relief when an IROPs causes an extended tarmac delay. A previous study, ACRP Report 112 (Griffith et al. 2014), found that most airports do not make explicit provision for persons with disabilities, including those using service dogs, in terminal evacu- ation, sheltering-in-place, and repopulation plans.