The Not-So-Friendly Skies

ALDF has urged the Federal Aviation Administration (FAA) to strengthen a series of proposed regulations concerning animals traveling in the cargo holds of airline planes. Responding to longstanding concerns about the issue voiced by the public and animal protection groups, Congress directed that airlines make public reports about incidents involving the loss, injury or death of animals during air transport while also improving the training of airline employees entrusted with animal care.

In the fall of 2002, the FAA sought public comment on the proposed regulations. ALDF analyzed the proposed regulations, as well as many of the public comments already on file, and found three primary areas of concern. First, the FAA's proposed definition of "animal" is unduly narrow, restricting "animals" to "pets," thus ignoring the vast number of transported animals who are not companion animals. Second, some public comments suggested that airlines need not investigate and report every incident, but only those where a formal complaint is filed. This would diminish the amount of timely, reliable data available to the public concerning the treatment of animals by various airlines. And third, the proposed regulation contains no provisions for improving employee training.

If the final regulation were to apply only to formal complaints about pets, with no additional training required, the FAA will have failed to implement the mandate of Congress and would be at odds with public interest in the safety of animals traveling by air. (To see the entire FAA rulemaking proceeding, including a copy of the proposed regulation, click here.)

ALDF submitted its analysis of the proposed regulations to the FAA in December of 2002. (To see these comments, open the document at the bottom of this page. You will need Adobe Acrobat Reader to view the document properly.) Before finalizing the regulations in the months ahead, the FAA must review and consider ALDF’s comments, as well as more than 5,500 comments submitted so far by other animal welfare organizations, airlines, animal dealers, exhibitors, researchers and thousands of concerned private citizens.

"We expect that the FAA will look closely at our comments and make the appropriate changes. We will continue to monitor the progress of these regulations and, when a final version is announced, we will examine it carefully and decide then whether further action is necessary," says Wendy M. Anderson, managing attorney of ALDF's D.C. Litigation Office.

Download ALDF's comments to the FAA here. (PDF)