FW: [GDUI Members Announce] Partnership in Action: The GDUI Advocacy Report

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Margie Donovan

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Jun 3, 2025, 2:16:00 PMJun 3
to GDUI BUSINESS (business@guidedogusersinc.org)

This is not representing our membership. I have seen no surveys. Mr. Brown claims to have spoken with people, but a survey needs to be conducted. Many, not myself, are happy with the self-identification option.

 

This in no way covers self-trained guide dogs with the airlines. We as members clearly have no say in what the Advocacy Committee is doing and what the board decisions are. The comment prior to a vote has never changed how the board votes.

 

GDUI is to represent all of its members. We can’t leave out owner trained guide dogs. This is allowed under the ADA. What are GDUI’s solutions for owner trainers to get an I.D. card?

 

If I were not a life member of GDUI I would leave. I have spoken with past presidents and I will not at this time withdraw my life membership. I want to, however. I will wait for this administration to move on and stop making decisions for all of us as handlers.

 

The fact that you Sarah appointed Mr. Brown as Advocacy Chair after what he so wrongly did in CA clearly states you do not care about other guide dog groups. For clarification Mr. Brown took the GDUC name in revenge. He never did anything with it other than to keep the well-known organization that existed in CA under the CCB since the early 80s from having it. This was horrible. Yes, we did not do the proper paperwork to stop this with the State, but again he did this in revenge. WE have a new and better name now. I will never work with Mr. Brown with the history he has. He totally supported at every Level Lori Meta. He thought she was great. He is dangerous to the guide dog movement.

 

The fact Sarah that you stated to me you did not care about what he did in CA when you appointed him made a loud and very clear statement about how you feel about us.

 

What does GDUI do for its affiliates???? I hope more leave GDUI. The answer is nothing accept for a monthly meeting. Affiliates can’t even post their newsletters on the GDUI lists. You told one affiliate to stop doing so.

 

GDUI is not the organization it used to be. I can’t wait for all terms to expire and a new and great leadership like we had prior to Lori and we have not since. GDUI has lost a lot of value in ACB.

 

Yes, Sarah, I am fully aware that you will probably have me suspended from the GDUI lists for telling the facts and truth. This will never stop me from being who I am and speaking out as a Lifetime GDUI member.

 

I want to thank our outstanding past Presidents, MJ, Kim, Sherry, Debbie, Jenine, Sheila, Becky and if I left anyone out, I am sorry.

Margie Donovan

 

From: pres...@guidedogusersinc.org <Pres...@guidedogusersinc.org>
Sent: Tuesday, June 3, 2025 8:58 AM
To: Announce list <anno...@guidedogusersinc.org>
Subject: [GDUI Members Announce] Partnership in Action: The GDUI Advocacy Report

 

Partnership in Action: The GDUI Advocacy Report

A Monthly Publication from the Guide Dog Users Inc. Advocacy Committee
Don Brown, Advocacy Committee Chair
Contact: advo...@guidedogusersinc.org
"Supporting guide dog handlers — one step at a time toward greater access and independence."
June 2025


In This Edition:

  • From the Chair – A Message from Don Brown
  • Working Together: A Path Forward for Airline Travel
  • Notice of Proposed Policy Statement on Drug and Alcohol Testing Programs for Transportation Network Companies (TNCs)
  • Guide Dog Users, Inc. Calls for the Immediate Discontinuation of Ride-Share Companies’ Self-Identification Programs
  • GDUI Reaches Out: Our Letter to Uber's Leadership
  • 🌟 Looking Back: How Advocacy Transformed Subway Safety
  • Small Steps, Big Impact: Small Claims Court as a Tool for Change
  • Good to Know: How State Laws Differ Across the Country

From the Chair – A Message from Don Brown

Dear Friends,

Welcome to the first issue of Partnership in Action: The GDUI Advocacy Report. We're excited to start this monthly conversation with you—one focused on building a stronger voice for guide dog handlers everywhere.

These pages will keep you updated on the important work happening quietly behind the scenes. You'll learn about our conversations with policymakers and our efforts to help businesses better understand access needs. We'll share practical tools for navigating challenges and resources to help you stay informed about your rights. Most importantly, you'll hear stories from our community that remind us why this work matters.

Many of us have noticed changes—sometimes subtle, sometimes stark—in how our access rights are respected. Maybe it's a restaurant host who seems uncertain, a ride that doesn't show up, or a hotel staff member who expresses "concerns" about your guide dog. While these moments might feel isolated, together they remind us that there's still work to do in protecting the independence we value so much.

This newsletter is here for you—a place to stay informed, find support, and be part of the conversation.

Thank you for being part of this important community. The journey toward full and equal access continues, and we're stronger when we walk it together—handlers and guide dogs, side by side.

In partnership,
Don Brown
Chair, GDUI Advocacy Committee


Working Together: A Path Forward for Airline Travel

At its April 3rd meeting, the GDUI Board of Directors adopted the following position statement.

GDUI Position Statement: Restoring Guide Dog Handlers’ Air Travel Independence — A Call for Airlines to Eliminate Overly Burdensome Documentation Barriers

Guide Dog Users, Inc. (GDUI) calls on airlines to immediately reform their documentation requirements for guide dog teams. Current Department of Transportation (DOT) attestation policies have turned what should be a straightforward right into a complex administrative burden, effectively limiting the independence of guide dog handlers through unnecessary bureaucracy.

Core Position
GDUI urges airlines to recognize and accept two existing professional documents as sufficient verification:

  1. Training program–issued photo identification for guide dog teams
  2. Current rabies vaccination certification from a licensed veterinarian

This streamlined approach, with documentation presented at the gate, would restore travel independence while maintaining legitimate safety protocols.

Supporting Evidence
The current system disregards six decades of impeccable safety performance by guide dog teams:

  • Zero reported incidents in millions of flight hours
  • Comprehensive training specifically for air travel environments
  • Professional certification and ongoing veterinary oversight
  • Rigorous public access standards that exceed basic requirements

Impact of Current Requirements
Today’s attestation policies:

  • Create needless technical and bureaucratic barriers
  • Impose advance notice requirements that are often inaccessible
  • Restrict spontaneous travel opportunities
  • Undermine the spirit and intent of access laws

Practical Solution
Our proposed verification approach would:

  • Restore travel flexibility and independence
  • Maintain safety and health through professional documentation
  • Eliminate the need for often-inaccessible advance submissions
  • Reduce administrative complexity for airlines
  • Provide more reliable verification than self-attestation

Legal Framework
The Air Carrier Access Act established clear access rights for guide dog teams. Current policies have eroded these protections through excessive administrative requirements. Our solution better serves both safety needs and legal obligations.

Call to Action
GDUI calls upon airlines to:

  • Acknowledge the proven track record of guide dog teams
  • Accept program ID and rabies certification as sufficient documentation
  • Eliminate advance submission mandates
  • Partner with guide dog organizations on implementation

Path Forward
GDUI stands ready to work with airlines to restore independence for guide dog handlers while maintaining appropriate health and safety standards. We seek to rebuild a system that honors both legitimate security concerns and the fundamental right of guide dog handlers to travel independently.


Position Statement: Guide Dog Users, Inc. Calls for the Immediate Discontinuation of Ride-Share Companies’ Self-Identification Programs

Guide Dog Users, Inc. (GDUI) stands firmly against ride-sharing companies' implementation of “voluntary” self-identification programs for guide dog handlers. These programs, though marketed as service improvements, create an inequitable system that undermines the civil rights protections guaranteed by the Americans with Disabilities Act (ADA) and related non-discrimination laws.

Core Position
Guide dog handlers already possess an unequivocal right to access transportation services without pre-notification or special identification. Any system that offers different levels of protection based on self-identification status directly contradicts these established legal protections.

The flaws in these programs are serious. They pressure individuals to disclose their disability status in advance to receive faster complaint resolution—a service that should be standard for all users. These programs lack transparency, with no data demonstrating their effectiveness in reducing discrimination. Most troubling, they imply that complaints from non-registered handlers are less deserving of urgent attention.

Critical Issues
Current self-identification programs compromise both rights and privacy by:

  • Creating a two-tiered system where prompt complaint investigation becomes contingent on advance disability disclosure
  • Establishing a concerning precedent that could spread to other public accommodation sectors
  • Operating without accountability or evidence of actual discrimination reduction
  • Implicitly devaluing complaints from handlers who choose not to self-identify
  • Reducing user agency and individual choice

Recommended Solutions
GDUI urges ride-sharing companies to adopt comprehensive, equitable practices, including:

  • Implementing swift investigation protocols for all discrimination complaints
  • Enhancing mandatory driver training on service animal rights
  • Establishing clear, consistent penalties for access denials
  • Designing privacy-protecting complaint systems
  • Collaborating with guide dog organizations on policy development
  • Providing public data on discrimination incidents and resolutions

Path Forward
GDUI calls for the immediate discontinuation of self-identification programs. We advocate instead for universal policies that protect all guide dog handlers equally. Our organization stands ready to collaborate with ride-sharing companies to develop effective, equitable solutions that address the widespread discrimination guide dog handlers face while preserving their dignity and rights.

We seek not just compliance with existing laws, but a genuine commitment to equal access—creating systems that work for everyone, not just those willing to sacrifice their privacy for basic rights.


Notice of Proposed Policy Statement on Drug and Alcohol Testing Programs for Transportation Network Companies (TNCs)

The Federal Transit Administration (FTA) is considering whether Transportation Network Companies (TNCs) like Lyft and Uber should comply with federal drug and alcohol testing requirements when providing paratransit services. While Uber seeks exemption under the "taxicab exception," safety advocates argue that this creates a dangerous double standard in public transit, particularly for vulnerable riders who rely on paratransit services.

Below you’ll find GDUI’s response to the FTA.


RE: Docket No. FTA–2024–0020

Notice of Proposed Policy Statement on Drug and Alcohol Testing Programs for TNCs

On behalf of Guide Dog Users, Inc., I am writing to express our strong support for the FTA's proposed policy statement clarifying the applicability of drug and alcohol testing requirements to Transportation Network Companies (TNCs) providing public transit services.

As an organization representing individuals partnered with guide dogs, we have a unique perspective on the critical importance of safety in public transportation. An increasing number of our members now rely on TNCs through paratransit programs for their daily transportation needs. While this integration of TNCs has expanded transportation options for guide dog handlers, it has also raised significant safety concerns when these services operate under different safety standards than traditional transit providers.

When our members board any vehicle—whether it's a traditional paratransit van or a TNC vehicle operating under a transit agency contract—they need absolute confidence that the driver is held to the highest safety standards. The current interpretation of the "taxicab exception" as it applies to TNCs has created an inconsistent safety environment that puts riders at risk, particularly those who cannot visually verify a driver's condition or behavior.

The FTA's proposed policy statement rightly recognizes that when TNCs enter into formal arrangements with transit agencies, they become an integral part of the public transportation system. This integration should carry the same responsibilities and safety requirements as other transit modes. We know this is achievable because several TNCs already successfully implement FTA-compliant drug and alcohol testing programs while maintaining efficient operations.

The clarification provided by this policy statement would:

  1. Ensure consistent safety standards across all transit services used by guide dog handlers
  2. Protect vulnerable riders who rely on paratransit services
  3. Maintain the integrity of public transportation safety programs
  4. Provide clear guidance for transit agencies and TNCs working with passengers who use service animals

For our members, the stakes are particularly high. Guide dog handlers must be able to focus on working with their dogs and navigating their environment without the additional concern of whether their TNC driver is held to the same safety standards as other transit operators. The current situation, where TNCs may operate under different safety requirements, creates unnecessary anxiety and risk for our community.

We particularly appreciate that the proposed policy statement does not restrict the use of TNCs in public transit; rather, it ensures that when TNCs participate in public transportation programs, they meet the same safety standards as other providers. This approach maintains innovation and expanded service options while protecting public safety.

Guide Dog Users, Inc. urges the FTA to finalize this policy statement as proposed. It represents a necessary step toward ensuring that all transit riders—including those partnered with guide dogs—receive the same level of safety protection that Congress intended when establishing drug and alcohol testing requirements for public transportation providers.

Respectfully submitted,
Don Brown
Guide Dog Users, Inc.
Advocacy Committee Chair


GDUI Reaches Out: Our Letter to Uber's Leadership

After the GDUI Board of Directors adopted its position statement, the chair of the Advocacy Committee sent the following letter to Uber’s CEO on April 17th.

GUIDE DOG USERS INC.
3603 Morgan Way
Imperial, Missouri 63052
TOLL-FREE: 1-866-799-8436
www.GuideDogUsersInc.org

April 17, 2025

Mr. Dara Khosrowshahi
Chief Executive Officer
Uber Technologies, Inc.
1455 3rd Street
San Francisco, CA 94158

Dear Mr. Khosrowshahi,

On behalf of Guide Dog Users, Inc. (GDUI), the nation's leading advocacy organization representing guide dog handlers, I write to formally convey our Board of Directors' decision urging Uber to discontinue its guide dog handler self-identification program, effective immediately. Please find our comprehensive position statement enclosed.

While we acknowledge Uber's expressed intention to improve service for riders with guide dogs, we believe the current structure of Uber's recently rolled out self-identification program is fundamentally incompatible with the civil rights protections guaranteed under the Americans with Disabilities Act (ADA). GDUI opposes this program on three principal grounds: its infringement on privacy, the creation of a discriminatory two-tier complaint resolution system, and the troubling precedent it sets for broader public accommodations.

First, the program compromises the right to privacy by effectively pressuring individuals to disclose their disability status in order to access timely complaint filing and resolution. Although Uber characterizes participation as voluntary, the operational reality reveals otherwise: those who opt into the program receive real-time engagement from Uber when service is denied, including immediate messaging and initiation of the complaint and resolution process. In contrast, guide dog handlers who choose not to disclose their disability status are required to independently initiate complaints through standard channels and experience significantly delayed resolution timelines. This disparity in treatment establishes an inequitable system that penalizes individuals for exercising their lawful right to privacy.

Second, this unequal structure constitutes a two-tier complaint process that we contend is both ethically indefensible and legally questionable. By offering expedited handling exclusively to those who disclose disability information, Uber is functionally creating separate classes of service—one for individuals who disclose a protected status, and one for those who do not. This framework violates the ADA's core tenet that individuals with disabilities must not be subjected to disparate treatment based on their unwillingness to disclose their disability status.

Third, the implications of Uber's model extend far beyond the ride-sharing industry. As a market leader in transportation innovation, Uber's practices carry influence across the service sector. If normalized, this model may invite similar policies in other industries, encouraging businesses to tie service quality or responsiveness to the disclosure of disability status. This would represent a serious erosion of the hard-won civil rights protections the ADA was designed to ensure.

We are further concerned by the absence of efficacy data demonstrating that the self-ID program reduces service denials. After two years of design, testing, and deployment involving “thousands” of riders and testers, Uber has not produced evidence to support the program's effectiveness.

Moreover, previous national legal settlements involving Uber and guide dog handlers established clear expectations for Uber's service delivery, including explicit requirements that have yet to be fully implemented:

  • Mandating equal service for passengers with disabilities and service animals
  • Implementing permanent removal of drivers who knowingly deny service based on a passenger's service animal
  • Establishing a zero-tolerance policy for drivers with multiple service refusals

These commitments represented concrete steps toward addressing systemic discrimination. Instead of focusing on these substantive solutions, Uber has introduced a self-identification program that shifts the burden of addressing discrimination onto guide dog handlers themselves.

GDUI brings significant expertise to transportation and access issues, as demonstrated by our landmark victory in Guide Dog Users Inc. vs. Hawaii. This case challenged Hawaii's discriminatory 120-day quarantine requirement for guide dogs—a policy that effectively barred guide dog handlers from visiting or relocating to Hawaii. Through strategic advocacy and litigation, GDUI secured a settlement that created a rabies-prevention protocol balancing public health with civil rights. This achievement transformed access not just in Hawaii, but established a national model for evidence-based policies that protect both public safety and disability rights while maintaining essential protections for all stakeholders.

GDUI remains committed to collaborating with Uber to develop effective, legally sound solutions. Drawing on our decades of experience, national network of guide dog users, and proven track record of policy success, we stand ready to help create meaningful improvements that enhance reliable transportation access while preserving essential civil rights protections.

Sincerely,
Don Brown
Chair, Advocacy Committee
Guide Dog Users, Inc.

cc: Sarah Calhoun, President, GDUI
Claire Stanley, Director of Advocacy and Governmental Affairs, American Council of the Blind
GDUI Board of Directors
GDUI Advocacy Committee
Chron file

Enclosure: GDUI Position Statement on Ride-Share Self-Identification Programs


🌟 Looking Back: How Advocacy Transformed Subway Safety

In the early 1990s, blind and visually impaired riders in the Bay Area came together to address a serious safety concern, showing how community advocacy can create lasting change.

The problem was clear to guide dog handlers and cane users: without tactile warnings at platform edges, a moment of confusion or a single misstep could be dangerous. Several blind riders had fallen onto tracks over the years, with some incidents having fatal outcomes.

Guide dog handlers were important voices in this movement. They helped others understand how both handlers and dogs needed clear, consistent signals to navigate platform edges safely. While organizations like the Disability Rights Education & Defense Fund, the California Council of the Blind, and San Francisco's Lighthouse for the Blind provided support, the real strength came from individuals who attended public meetings and BART board sessions with their guide dogs.

These advocates did more than just express concerns—they built a strong case. They carefully documented incidents and near-misses, turning statistics into personal stories that people could understand. Their experiences helped move this issue from a low priority to an urgent public safety matter.

The timing was helpful too, as the Americans with Disabilities Act was taking effect and providing new frameworks for accessibility. Detectable warning tiles—those raised strips you feel underfoot—were recognized as essential safety features. Thanks to persistent advocacy, BART became the first major transit system in the country to install them comprehensively.

The results were significant and immediate. Blind and low-vision riders—and their guide dogs—could now detect platform edges through touch and training, greatly reducing fall risks. Guide dogs could learn to recognize these tactile markers, adding another layer of safety.

This success helped establish standards that now benefit millions of blind and visually impaired passengers nationwide. Those tactile strips serve as a reminder of what thoughtful advocacy can accomplish.

The BART safety campaign reflects the same principle that guides GDUI's work today: when guide dog handlers join together, they can create meaningful, lasting improvements that help many people for years to come.


Small Steps, Big Impact: Small Claims Court as a Tool for Change

When you face discrimination with your guide dog, small claims court can be a practical option that many handlers don't consider. This accessible approach can provide accountability without the complexity and expense of traditional lawsuits.

Small claims courts exist in every state as user-friendly places designed for people without lawyers. For guide dog handlers denied access to businesses, transportation, or housing, these courts offer a straightforward way to seek compensation for discrimination.

The process typically involves modest filing fees (often $30–$100) and simplified paperwork. Many courts offer fee waivers for those with financial challenges. Several states specifically allow discrimination claims in small claims court, with damage limits usually ranging from $5,000 to $10,000.

While small claims courts can't require businesses to change their policies, they can award compensation for various harms—such as extra transportation costs, expenses from service refusal, emotional distress, or statutory damages.

Good documentation helps: save receipts, take notes right away, get witness information, and record staff names when possible. These details can strengthen your case.

Small claims court isn't the right choice for every situation, but it's a valuable tool that can make justice more accessible for guide dog handlers facing discrimination.

Important Note: Not all state small claims courts accept public accommodation and housing discrimination cases. Some states may limit small claims to certain types of disputes or have specific procedures for civil rights cases. Before filing, check with your local small claims court or state court system to confirm they handle discrimination claims. Your state's disability rights organization or legal aid society can also provide guidance on the best legal options in your area.


Good to Know: How State Laws Differ Across the Country

While the Americans with Disabilities Act provides national protections for service animals, state laws add their own elements—sometimes expanding protections, sometimes creating helpful clarifications. This variety can be confusing for both guide dog handlers and businesses, especially when traveling between states.

Here’s how state laws typically vary:

Service Animal Definitions: Most states follow the ADA's definition (dogs or miniature horses trained to assist people with disabilities), but some expand or modify it.

Public Access: All states meet ADA requirements for service dog access, but some provide additional protections or specify how rules are enforced.

Protection from Harm: Nearly every state except Alaska, Iowa, Montana, and West Virginia has laws against interfering with, stealing, or harming service animals, though specifics and penalties vary.

Service Dogs in Training: Most states allow access for dogs in training programs, with Hawaii being the exception.

Licensing and Fees: Some states prohibit special fees or require identification for service dogs, while others treat them like regular pets for licensing purposes.

Fraud Prevention: Over 30 states have penalties for misrepresenting pets as service animals, with varying definitions and consequences.

Breed Restrictions: Federal law prohibits breed-based restrictions for service animals, but local rules vary; exceptions must be made unless an individual animal poses a direct threat.

Federal vs. State Protections: Federal ADA protections set the minimum standard. States can't offer less protection but can provide more or broader protections.

Why This Matters: These differences can create confusion for both handlers and businesses. What's clear in one state might be less clear in another. GDUI works toward consistent protections nationwide and helps members navigate this complex landscape.

For detailed state-by-state information, the Animal Legal & Historical Center maintains a helpful database at: https://www.animallaw.info/topic/table-state-assistance-animal-laws.


That's our first issue of Partnership in Action: The GDUI Advocacy Report. This newsletter represents GDUI's commitment to keeping you informed, engaged, and supported in working toward equal access and rights.

Do you have an advocacy story to share? Questions about your rights? Ideas for future articles? We'd love to hear from you! Contact us anytime at advo...@guidedogusersinc.org with your stories, questions, and suggestions.

Until next time, keep moving forward—and keep advocating with every step.

In partnership,
Don Brown
GDUI Advocacy Committee Chair

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