This is a template for a letter and can be adjusted *based on your personal views.* This template asks for MLA and MP to create a fair National service dog standard and asks that certification by provinces be considered proof of training. 

To Whom It May Concern

The recent changes (March 2021) by the Canadian Transportation Agency regarding flying with a service dog have put undue hardship on handlers of owner trained service dogs flying within Canada and internationally.

As stated in the act below, only dogs trained by an organization or person specializing in service dog training are allowed on flights.

Transportation of Service Dogs
Duty to transport

51 (1) A carrier must, on the request of a person with a disability who needs to travel with a service dog, accept the service dog for transport and permit the animal to accompany the person on board, subject to subsection (2).
Requirements
(2) A carrier may require a person with a disability who requests to travel with a service dog to control the dog with a leash, tether or harness during travel and to provide

(a) at the time that the person with a disability makes the reservation with the carrier, a declaration attesting that the service dog has been individually trained by an organization or person specializing in service dog training to perform a task to assist the person with a disability with a need related to their disability; and
(b) before departure, an identification card or other document that is issued by an organization or person specializing in service dog training that identifies the person with a disability and attests that the service dog has been individually trained by the organization or person to perform a task to assist the person with a disability with a need related to their disability.

https://laws-lois.justice.gc.ca/eng/regulations/SOR-2019-244/FullText.html

Many service dogs in Canada are owner-trained for various reasons.

- Handler doesn’t qualify for a non-profit program dog (most programs train for specific tasks for specific disabilities and these tasks do not meet the needs of every disabled individual, e.g. guide dogs such as seeing eye dogs, hearing dogs, or assistance dogs for veterans suffering from PTSD).
- Wait times for program dogs are very long (years at times).
- Handler can’t afford to buy a dog from a for-profit organization (costs average $25’000 - $35’000).
- Handler has difficulty accessing or affording to hire a private trainer to train their service dog.
- There is no specific service dog training in Canada.
- Training a service dog takes about 2-3 years from puppyhood and is a very time-consuming, intense process. While even owner training is expensive, it is far less costly than acquiring a program dog or sending a dog to a trainer for months.
 
Based on the above information, I hope that you can appreciate the need for owner trained service dogs.

While I understand why the rules have changed, as there were issues with untrained service dogs and emotional support animals at airports and on flights, the new rules make it impossible for handlers of owner-trained service dogs to fly internationally with their service dog.

While I support the right of any Canadian with a disability’s right to train their own service dog, I also feel that service dogs need to be held to a certain standard. Currently only British Columbia, Alberta, and Nova Scotia have a voluntary certification for guide and service dogs. However, if I understand correctly, at this point Air Canada (and other airlines) don’t accept provincial certification of a service dog.

There is a push for a national standard for certification of service dogs (https://www.cbc.ca/news/politics/conservatives-national-standards-service-dogs-veterans-1.6129085?fbclid=IwAR0IboZ3ps0zfGnMgXIjR_XqbGkvD_r0AMhPg1OlqZWXSDf35fNA2FdaC6g however, this could still take years.

Here are some points suggested by service dog handlers I talked to, which I hope the Canadian Transportation Agency and airlines are willing to consider:

There needs to be a list of trainers from each province from which the airlines will accept evaluations. That way a handler wishing to travel by plane can get an evaluation from an approved trainer which grants access without further problems. Currently airlines can arbitrarily decide not to accept a trainer.

Provincial guide and service dog certification from the provinces of British Columbia, Alberta and Nova Scotia should be recognized. Provincial certification testing is done to ADI (Assistance Dogs International) standards. By accepting provincial certification, airlines would recognize the need for owner trained service dogs while still ensuring that all service dogs on flights have been tested and meet the ADI standards for a service dog.
Service dogs should be able to get approved beforebooking a flight.
Airlines should keep files of accepted service dogs on file (just like VIARail does).
There needs to be a clear outline what documents are required in order to bring an owner trained service dog on a plane. Airlines are not very forthcoming with regards to which specific documentation is required for owner trained service dogs.

Airline staff needs to be better trained in understanding the service dog community (the difference between owner training, using a trainer to help with training, organization training). Program dogs aren’t necessarily better trained than owner trained dogs.

On behalf of the greater service dog community, I would very much appreciate your help with this matter in helping me get this information and request to the right channels.

Thank you for your time.

Sincerely,