The Not-So-Friendly Skies

Posted on January 2, 2003

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)