Joanna Lubkin, a Unitarian Universalist minister, has chronic pain and fatigue and relies on her service dog, a 4-year-old black Labrador named Sully, to pick up items she drops, press elevator buttons and brace her when her body weakens. She never travels without him.
In June, when she and Sully arrived at the Pittsburgh International Airport to fly home to Boston after a conference, the agent at the JetBlue Airlines gate told her that there were no forms on file certifying Sully as a service dog, and refused to let her board.
Since 2021, the Department of Transportation has required travelers with disabilities to fill out a standard form before boarding an aircraft with their trained service animal, attesting to the dog’s health, behavior and training. Before her flight to Pittsburgh on Delta Air Lines, Ms. Lubkin, 37, had completed the D.O.T. form for both Delta and JetBlue and uploaded it to their websites. With Delta, she experienced no issues.
But a week later she found herself stranded in Pittsburgh, confused and frustrated. She did not know she was only one of many travelers with disabilities encountering hurdles with the verification process, and finding themselves stuck at the airport even after they had correctly verified their service dogs for air travel.
JetBlue is one of four airlines that uses a third-party — a small, Chicago-based company called Open Doors Organization — to review the new D.O.T. forms and issue approvals or denials on their behalf. And when Ms. Lubkin arrived at her gate for her return flight home, she was told Open Doors had not verified her form, and she would not be allowed to fly.
Angry and tired, Ms. Lubkin called a friend, who offered to drive her 570 miles back to Boston.
“Flying is physically painful for me and for a lot of people,” she said. “Making it that much harder for us to travel is just unjust, and it doesn’t feel right to me.”
A JetBlue spokesman acknowledged her concerns.
“We understand that we need to ensure better consistency in verifying paperwork during travel on all flights of a customer’s itinerary,” said Derek Dombrowski, the airline’s senior manager for corporate communications.
‘I consider that discrimination’
Before the coronavirus, air travelers looking to bring an animal into the cabin had to adhere to airlines’ individual rules for flying with pets, which sometimes required the purchase of a special ticket. Fully trained service animals were exempt from any charges.
Airlines say the 2021 regulations were needed after a pandemic-related uptick of pets on airplanes, many of them untrained and presenting a risk to travelers and legitimate service animals alike. There were also a number of incidents where passengers attempted to pass off pets or emotional-support animals as trained service animals. At the end of 2021, most major airlines had declared they would no longer accept emotional-support animals on board, and the Transportation Department put forth new rules for service animals.
Among the changes: Airlines can require users of service animals, which are defined as dogs trained to perform a task directly related to an owner’s disability, to submit a D.O.T. form attesting to the animal’s health, behavior and training.
JetBlue, Allegiant Airlines, Sun Country Airlines and Alaska Airlines have partnered with Open Doors to process the forms. Travelers upload their forms to the airlines’ websites, and the airlines then pass them on to Open Doors, which verifies the legitimacy of the service dog by examining the form and sometimes calling the trainer, whose contacts are required on the form, with additional questions.
Other airlines, including American Airlines and United Airlines, review and approve the forms themselves.
Some dog trainers and disability advocates say the new rules may be illegal.
After Ms. Lubkin filled out her D.O.T. form and uploaded it to JetBlue’s website, more than a week before departure, she received an email from NEADS, the service dog organization that trained Sully, letting her know they had been contacted by Open Doors regarding her form and she was “all set.”
But in Pittsburgh, the gate agent couldn’t find any communication from Open Doors in her file.
“The fact that a corporation is making it so difficult for somebody to get accommodations for their disability — I consider that discrimination,” Ms. Lubkin said.
Travelers on other airlines have also faced issues. In June, Ashley O’Connor, a stay-at-home mother of three, was eager to fly home to Columbus, Ohio, from Myrtle Beach, S.C., with her son, Owen, and his new service dog.
Owen, 4, has CHARGE syndrome — an acronym for a genetic illness affecting the heart and airways — and Téa, a German shepherd, was trained to alert people around her when Owen is at risk of respiratory distress.
Three days before their return flight on Allegiant, Ms. O’Connor, 30, filled out the D.O.T. form on the Allegiant’s website, but was told her application was denied because she didn’t list the specific tasks for which the dog is trained. She filled it out again, resubmitted and then received a confirmation. An email from Open Doors came next, saying she could “request travel” from Allegiant. She did.
At the airport however, Ms. O’Connor was told there were no forms on file. She tried to submit them yet again with her phone, at one point pausing at the check-in counter to suction Owen’s tracheostomy tube. But she received a series of error messages, and was eventually told by the Allegiant gate agent that her application was denied.
She had to enlist the help of Owen’s great-grandparents, both in their late 70s, to drive Téa nearly 10 hours to Columbus. She flew home alone with Owen.
“My obviously disabled child was sitting in a stroller next to me,” she said of the incident at the check-in counter. “There was no compassion.”
Allegiant said that Ms. O’Connor’s application was held up due to incomplete information, and that she did not inform the airline she was traveling with a service animal until she arrived at the airport. She contests this.
“Open Doors Organization is a trusted nonprofit disability advocacy organization,” a spokesperson with the carrier said. “This strategic partnership has equipped Allegiant with better tools to serve the disability community, allowing us to streamline the service animal approval process while ensuring the safety of all passengers and crew members.”
Open Doors has admitted that communication with the airlines at times has gone awry. But the organization’s founder, Eric Lipp, said the issue mostly stemmed from airline workers who lacked proper training.
“We have had a couple of hiccups,” Mr. Lipp said. But when paperwork issues arise, he added, airline workers should allow customers with a clear disability to board, or reach out directly to Open Doors for guidance in that moment.
“JetBlue and Allegiant take up 90 percent of our time,” he said, adding that airlines should call the organization for input before issuing a denial. “Sometimes the people who work for the airlines just do stuff. And we don’t want the people at the airport to be the ones making the decisions.”
Passed off as service animals
The Air Carrier Access Act, passed in 1986, requires airlines to allow travelers with disabilities to board a flight with their service animals. And it limits the questions airlines can ask about a traveler’s disability as well.
“There are certain reasons an airline can deny a service animal, such as if it’s not a dog or if they see behavioral issues,” said Cait Malhiot, an attorney with Marko Law, a law firm in Detroit. But an airline can’t require passengers to show any specific training for a dog, or that a dog be trained only by an accredited source.
Ashley Townsend, a 32-year-old social worker, is blind and relies on Lolly, a 3-year-old black lab. In June, Ms. Townsend was invited to fly from her home in Denver to a fund-raiser in New York City for a guide-dog conference. The organization booked her ticket on JetBlue, and Ms. Townsend called the carrier two days before her flight to ensure she wouldn’t face issues boarding with Lolly. She was assured that she was all set to fly.
But the next day, Ms. Townsend used her screen reader to look at JetBlue’s website. Only then did she see that her D.O.T. form, which she was used to submitting, would have to be reviewed by Open Doors before flying. She had flown just two months earlier with Lolly on a Southwest Airlines flight and not encountered an Open Doors review. When she received an automated message that it would take 48 hours to receive a response, she panicked — her flight was in less than a day. She again called JetBlue, and after hours on hold, was informed that she had not completed the paperwork properly and would not be allowed to fly.
She canceled her ticket and purchased a new flight on United, which does not use Open Doors. She and Lolly flew without issue.
JetBlue said the Open Doors partnership had been put into place because of multiple incidents of dogs being passed off as service animals on flights, but then wreaking havoc in the air, including biting crew members and relieving themselves on the plane.
“We have developed a process to attempt to distinguish properly trained service dogs traveling with a qualified individual with a disability from other dogs,” said Mr. Dombrowski, the airline’s spokesman.
Ms. Townsend said she understood the rules have been tightened, but she feels that the disability community is bearing the brunt of the responsibility for an issue they did not cause.
“I’m faced with this burden of proving that my service animal is legitimate, instead of people being held accountable for intentionally blurring that line,” she said.
In May, Erin Brennan Wallner, a Jacksonville, Fla.-based communications associate, and her family were left stranded in Boston with their son’s service dog. Mason, 14, has autism and relies on Zoe, a 65-pound goldendoodle in moments of stress.
The family booked a vacation to Boston and was unaware of the change in the D.O.T. rules. So were the agents and crew on their outbound JetBlue flight — they flew with Zoe from Jacksonville to Boston with no issues. But when they arrived at the airport to return home, they were told they could not board without an approved D.O.T. form.
Frantic, Ms. Wallner attempted to fill out the form in the airport. The family watched their flight depart without them, and two hours later, while still hoping to be rebooked that day, Ms. Wallner received an email from Open Doors stating that Zoe, who was trained by a company called Off Leash K9 Training, did not qualify as a service animal.
Open Doors, when contacted about the situation, said that Zoe had been rejected because Ms. Wallner had used vague language to describe the dog’s training, rather than offering specifics on the tasks the dog performs. Mr. Lipp, Open Doors’ founder, said his company processes about 120 forms a day and in cases like Ms. Wallner’s, he always attempts to contact the trainer for more information.
But Zoe’s trainer, Matt Gregory, said he never received a call from Open Doors. The family ended up renting a car and driving 18 hours back to Jacksonville.
Ms. Wallner said that the fact her family was allowed to fly to Boston in the first place proved the system is not working.
“I understand that plenty of people take advantage of the situation,” she said. “But don’t you have a responsibility to at least get us home?”
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