June 27, 2024
Ashley Altenburger, J.D.
Division of Global Migration Health
Centers for Disease Control and Prevention
1600 Clifton Road, NE
Atlanta, GA 30329
RE: CDC Docket No. CDC-2023-0051, RIN 0920-AA82
Dear Ms. Altenburger:
The National Federation of the Blind, the transformative membership and advocacy organization of blind Americans, requests that the Centers for Disease Control and Prevention add an exception to the recently published Control of Communicable Diseases; Foreign Quarantine: Importation of Dogs and Cats Final Rule (RIN 0920-AA82) for service animals such as guide dogs for the blind.
The new rule requires a person, including a blind person using a guide dog, to complete and submit an online form, and present a receipt of that transaction every time they enter the United States. However, it makes no provision to ensure that assistance completing and submitting those forms is afforded to a person who requires such assistance due to a disability. As we stated to the Department of Transportation in our petition for exemption from 14 C.F.R. §§ 382.27(b)(3), 75, and 79 of the Air Carrier Access Act regulations (Docket No. DOT-OST-2018-0068), such a failure by an agency violates Section 504 of the Rehabilitation Act. The facts and argument set forth in that petition are equally or more applicable to the regulation of blind people crossing the border with a guide dog.
In addition, the burdens imposed by the new rule fall far more heavily on users of service animals such as blind persons using guide dogs than on others. Our guide-dog-using members who live near the Canadian border frequently travel between Canada and the United States, sometimes multiple times per week. Unlike non-disabled persons, they cannot simply leave their dog at home to avoid the burdens of the new rule. Further, they risk being stranded outside the United States if they are unable to complete the necessary online forms, effectively stranding them solely due to their disability.
If an amendment to provide an exception is not possible, we ask that Centers for Disease Control and Prevention delay implementation of the new rule pending issuance of guidance that will ensure that no person with a disability suffers discrimination crossing the border due to their use of a service animal such as a guide dog, or pending a new rulemaking to so ensure if such a new rulemaking is required.
Thank you for your attention to this matter. We would be happy to discuss our request at your convenience.
Sincerely,
Mark A. Riccobono, President
National Federation of the Blind