Decision No. 327-AT-A-2008

Amended by Decision No. 66-AT-A-2009

June 20, 2008

IN THE MATTER OF Decision No. LET-AT-A-30-2008 issued February 11, 2008 - Robin East against Air Canada and Jazz Air LP, as represented by its general partner, Jazz Air Holding GP Inc. carrying on business as Air Canada Jazz (Air Canada Jazz).

File No. U3570/06-17

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BACKGROUND

[1] In Decision No. LET-AT-A-30-2008 (the Show Cause Decision), the Canadian Transportation Agency (the Agency) made a preliminary ruling with respect to an application filed by Robin East which raised concerns over the amount of floor space that Air Canada and Air Canada Jazz (the carriers) provide for service animals and the carriers' practices with respect to assigning seats to passengers travelling with service animals.

[2] Mr. East is blind and travels with his service animal for mobility and safety. At the time of booking, which was more than 48 hours prior to Mr. East's flight departure, the carriers were made aware of his disability and the accommodation he required, i.e., that he be assigned a seat which provided sufficient space to accommodate his 85-pound guide dog.

[3] However, on Air Canada flight AC137 from Toronto to Vancouver, Mr. East experienced unnecessary negative attention when, as a result of the insufficient floor space for himself and his service animal, his guide dog encroached on the floor space of the passenger beside him. The passenger seated next to Mr. East entered into forceful discussions with the carrier personnel for approximately 25 minutes, voicing his dissatisfaction with the situation, that was witnessed by other passengers. The situation ended when the passenger decided to leave the aircraft, which caused a delay in the flight's departure as the passenger's baggage had to be off-loaded.

[4] On a second flight, AC8576 from Vancouver to Saskatoon, which was operated by Air Canada Jazz and booked to capacity, Mr. East experienced extreme discomfort due to insufficient space provided for him and his guide dog. Although the passenger seated next to Mr. East accepted the situation, unlike the passenger on Flight No. AC137, the passenger still had to place his feet in the aisle and move them back in front of him to permit passage of the trolley or of other passengers. Mr. East's service animal had to continually move from a "down to a sit" position because of the inadequacy of the space provided which resulted in the flight attendant instructing Mr. East to have his dog stay in the down position. Mr. East, for his part, felt compelled to tuck his legs under the seat as far as possible to make room for his service animal; his legs were locked in a cramped and uncomfortable position for the entire flight; as they were pushed far under the seat with only his toes on the floor. When Mr. East arrived at destination, his knees were sore and swollen due to the insufficient space provided to him and his service animal.

[5] The carriers' policies and procedures with respect to seating persons with disabilities who travel with service animals are as follows:

Chapter 57-MEDA Impaired Vision-Hearing submitted by the carriers provides the following text under "Definition of Service Animals":

• an animal (i.e., a dog or monkey) that is certified and professionally trained to assist a person with a disability.
• must be harnessed and seated at the passenger's feet.
• are carried free of charge when accompanying a passenger in the cabin or when carried in the baggage compartment even if the customer happens to have a travelling companion.

...

Chapter 57-MEDA Impaired Vision-Hearing sets out the following concerning, in part, passengers travelling with service animals:

• these passengers may be seated anywhere, except in emergency exit rows and in row 12 of A319, A320 and A321.
• hospitality class seats that have more surrounding floor and/or are considered to be the most appropriate for travel with a service animal have been identified on each aircraft type.
• all seats located in the executive/executive first cabin are adequate for service animals.
• determination of appropriate seat should be done in consultation with the passenger.

[6] The carriers submitted that their policy does not guarantee two seats for a passenger unless the passenger pays for the second seat at 50 percent of the price of the first seat, except if the passenger pays a Tango fare, the most discounted fare offered, in which case the 50-percent reduction for the second seat is not available.

[7] The carriers further explained that there is no "one document" relating to the assignment of seats for persons with disabilities, as seat assignment will depend on the aircraft and type of ticket purchased. Should the ticketed fare not allow advance seat selection, the carriers will note the seating requirement (e.g. a liftable armrest) and will advise the passenger that a seat meeting his/her needs will be provided. If, however, there is a very limited number of seats that meet the passenger's requirements and the only means of ensuring that the seat is assigned to the passenger is to pre-select the seat, the agent will assign one of those seats to the passenger. The carriers added that certain seats, such as the bulkhead seats on the A330 aircraft, are kept for airport assignment and are assigned last. Furthermore, if regulations impose certain restrictions on who can sit in a specific seat (e.g., the exit row), these seats will only be assigned at the airport so that the agent can appropriately assign them.

[8] The carriers further advised that although many seats are designated for passengers with disabilities, disabilities may vary and no seats are specifically designated seats for persons with disabilities accompanied by service animals. The carriers stated that the bulkhead in the Economy Class cabin on the A330 is used, generally with satisfaction, by passengers with disabilities travelling with a service animal.

[9] During the pleadings process, the Agency advised the parties that it is addressing this application in the context of section 149 of the Air Transportation Regulations, SOR/88-58, as amended (the ATR). Under the ATR, Canadian air carriers providing domestic air services using aircraft with 30 or more seats are required to accommodate persons travelling with service animals. Specifically, section 149 of the ATR provides as follows:

1. Subject to section 151, an air carrier shall accept a service animal for carriage without charge if the animal is
   
   1. required by a person for assistance; and
   2. certified, in writing, as having been trained to assist a person by a professional service animal institution
2. Where an air carrier accepts a service animal for carriage pursuant to subsection (1), the air carrier shall permit the animal, if the animal is properly harnessed in accordance with standards established by a professional service animal institution, to accompany the person on board the aircraft and to remain on the floor at the person's passenger seat. (emphasis added)

[10] Section 151 of the ATR provides, in part:

(1) Where a person requests a service set out in this Part at least 48 hours before the scheduled time of departure of the person's flight, the air carrier shall provide the person with the service.

...

(3) Where a request for a service referred to in subsection (1) or (2) is not made within the time limit provided thereunder, the air carrier shall make a reasonable effort to provide the service.

...

[11] In this case, given that the issues raised in Mr. East's application are covered by provisions in the ATR, the Agency's investigation is based on a determination of whether the carriers complied with the applicable regulations.

[12] Where the Agency is satisfied that regulations made under subsection 170(1) of the Canada Transportation Act, S.C., 1996, c. 10, as amended (the CTA) have been complied with, the Agency must determine that there is no undue obstacle to the mobility of persons with disabilities and the case will be dismissed. Equally, if the Agency concludes that there has been a regulatory contravention, it will necessarily result in a finding that the situation constitutes an undue obstacle, including a determination of appropriate corrective measures pursuant to subsection 172(3) of the CTA.

PRELIMINARY RULING

[13] The Agency set out its interpretation of subsection 149(2) of the ATR in the Show Cause Decision. The Agency is of the opinion that it is implicit in subsection 149(2) of the ATR that carriers must provide "sufficient floor space" to permit the service animal to remain on the floor at the person's seat while ensuring that both the person with a disability and the service animal can travel safely. The wording of the regulation would not reasonably support any other construction. It would not be reasonable to interpret the regulation such that a carrier could be found to have complied with it where the space provided to the person and the service animal may result in injury and/or extreme discomfort with the resulting negative impact on the person's well-being and/or on the animal's ability to adequately complete the duties which it is trained to perform.

[14] In its Show Cause Decision, the Agency accepted that Mr. East is a person with a disability and determined, on a preliminary basis, that the carriers contravened subsection 149(2) of the ATR as the evidence shows that the floor space provided at the seats in question was insufficient.

[15] In addition, the Agency considered the carriers' policy of charging passengers with disabilities an extra fee to secure a guarantee of additional floor space for their service animal by booking the adjacent seat. The Agency determined, on a preliminary basis, that:

• the application of the carriers' policy to persons with disabilities who travel with service animals on domestic flights, which guarantees the adjacent floor space in front of the second seat for the exclusive use of their service animal at a cost, in those cases where this is necessary to adequately accommodate the person and their service animal, constitutes a contravention of subsection 149(1) of the ATR as sufficient space for a service animal to remain with the person with a disability must be made available to that person at no additional charge.

[16] In light of the preliminary finding of the carriers' contravention of section 149 of the ATR, the Agency found, on a preliminary basis, that the following constituted undue obstacles to Mr. East's mobility:

• the floor space provided for Mr. East's service animal at the seat initially assigned to Mr. East and the difficulties he experienced upon boarding and before the commencement of Air Canada Flight No. AC137 as a result of the carriers' practice of attempting to provide accommodation at no additional cost to persons who travel with service animals for which the floor space at the assigned seat is insufficient; and,
  • the floor space provided for Mr. East's service animal at the seat assigned to Mr. East on Air Canada Jazz Flight No. AC8576.

[17] The Agency made a preliminary ruling that the carriers should, within a 90-day period following the issuance of the final determination, take the following corrective measure, as it applies to service animals as described in subsections 149(1) and 149(2) of the ATR:

• Develop policies and procedures to ensure that at the time of reservation, and upon receipt of a request at least 48 hours prior to the scheduled flight departure, the carriers will provide certainty that the person will be assigned seating with sufficient floor space at no additional cost. In this way, the carriers have the flexibility of delaying the assignment of a specific seat, provided they guarantee that appropriate accommodation will be provided. The determination concerning the seating accommodation that will be provided shall be made:
  • through dialogue with the person with a disability travelling with a service animal;
  • by reference to the floor space available at seats within the aircraft for use by the person and the service animal; and
  • by reference to the amount of floor space needed to accommodate the service animal.

[18] The Agency stated that these policies and procedures must also include provisions setting out that, where such a request is made less than 48 hours prior to departure, the air carrier will make a reasonable effort to provide the service.

[19] This corrective measure was determined necessary by the Agency to ensure compliance with subsections 149(1) and 149(2) of the ATR and, thereby, eliminating the undue obstacles, which the Agency found on a preliminary basis were experienced by Mr. East, and to leave as much discretion as possible with the carriers to develop appropriate policies and procedures in consideration of their specific equipment and operations.

[20] The Agency directed the carriers to provide specific evidence and related arguments to show cause why they have not contravened section 149 of the ATR, why the obstacles are not undue and why they should not be required to implement the corrective measure.

ISSUE

[21] This decision will address whether the carriers have shown cause why they have not contravened section 149 of the ATR and why they should not be required to implement the corrective measure.

CARRIERS' RESPONSE TO THE SHOW CAUSE DECISION

[22] The carriers disagree with the Agency's interpretation of section 149 of the ATR, which they submit imposes only the following two requirements:

1. carriers must accept a service animal onboard in the cabin at no additional charge; and
2. carriers must allow the service animal to sit at the person's feet.

[23] The carriers submit that, in Mr. East's case, they met the requirements set out in section 149 of the ATR by accepting his service animal at no additional charge and allowing the service animal to stay at the passenger's seat for the duration of the flight.

[24] The carriers state that the ordinary meaning of section 149 of the ATR is clear and that a requirement that the carriers guarantee, at the time of booking, that a person will be provided with sufficient floor space for a service animal at no additional charge cannot be read into the provisions. Where a request for a reservation is made at least 48 hours in advance, the carriers explain that they will generally not know whether there will be other open seats on the flight. Given both safety considerations that apply to bulkhead seats, as well as the fact that customers are free to purchase tickets at any time before the departure of the flight, the policies that the Agency is asking the carriers to implement effectively amount to reading a requirement that an additional seat must be provided to a person travelling with a service animal at the time of booking.

[25] The carriers assert that they make an effort to maximize the space provided to passengers travelling with service animals at the time of check-in and/or boarding, but that there are no regulatory requirements that they must take these measures ahead of time, nor that they provide a person with a service animal with an additional seat at the time of reservation. The carriers request that the Agency clarify the Show Cause Decision by confirming that in no case can a carrier be required to provide an extra seat, without charge, for the accommodation of a service animal and that any such requirement could be imposed, if at all, only after amendment of section 149 of the ATR.

[26] The carriers add that section 149 of the ATR can and should be construed as importing a requirement of reasonableness on the part of the person seeking the accommodation. The carriers state that "the person seeking the accommodation should be reasonably expected to equip himself with a service animal capable of occupying the floor space at the person's feet."

[27] The carriers submit that, while the Agency may have a genuine concern for the situation that occurred, this does not give it license to address its concerns by adopting an overly broad reading of section 149 of the ATR. The carriers recognize that the intent of providing accommodation to persons with disabilities is a valid and important goal of the CTA and Part VII of the ATR. The carriers state, however, that where the Agency has been tasked with setting out the requirements to meet this goal through regulations and these regulations impose clear requirements, the Agency cannot go beyond the limits of these requirements out of concern or sympathy for the claimant in a particular case. The carriers further state that, in other words, purposive interpretation of a statute cannot be used to achieve a certain objective at all costs.

[28] The carriers are of the view that the Agency has adopted an improperly expansive interpretation of section 149 of the ATR. The carriers suggest that to change requirements by means of expansive statutory interpretation would be fundamentally unfair to the air carriers in terms of: their ability to have an input into the requirements imposed on them; the manner in which the Agency approaches the issue (openness in the consultation process vs. ensuring compliance in the adjudicative process); and their ability to operate with some level of certainty as to what regulations require of them.

ANALYSIS AND FINDINGS

[29] As indicated in the reasons that follow, the Agency finds that the carriers have not shown cause that they have not contravened section 149 of the ATR.

[30] This case is about the proper interpretation of section 149 of the ATR and whether the carriers complied with this provision. The Agency agrees with the carriers that under modern principles of statutory interpretation, a purposive, rather than a liberal approach is required.

[31] Consequently, a valid method of interpretation would be to examine the general tenor of the wording used in section 149 of the ATR in light of the overall approach and spirit of the legislative scheme as a whole.

[32] The regulatory requirement of section 149 of the ATR sets out that, subject to the 48-hour advance notice requirement of section 151 of the ATR, the air carrier must:

1. carry the service animal free of charge; and,
2. permit the service animal to remain on the floor at the person's passenger seat.

[33] When the provisions of section 149 of the ATR are considered in the context of the CTA and the Agency's mandate to remove undue obstacles to the mobility of persons with disabilities, it would not be reasonable to interpret the regulation such that a carrier could be found to have complied with it where the space provided to the person and their service animal is less than sufficient and may result in injury and/or extreme discomfort with the resulting negative impact on the person's well-being and/or on the animal's ability to adequately complete the duties which it is trained to perform. The Agency finds that the wording would not reasonably support any other construction than that of sufficient floor space to permit the service animal to remain on the floor at the person's seat while ensuring that both the person with a disability and the service animal can travel safely. This interpretation is compatible with the purpose of the CTA with respect to accessibility issues, which as noted above, is to remove barriers for persons with disabilities in the federal transportation network.

[34] The carriers refer to University of British Columbia v. Berg, [1993] 2 S.C.R. 353, and submit that, in analyzing the provincial human rights legislation, the Supreme Court stated that, while on one hand, a generous and liberal reading should be accorded to "quasi-constitutional" human rights legislation; on the other hand, interpretation could not be stretched so far beyond the wording of the actual statute that the broad purpose overtakes what the statute actually says.

[35] Even though the space provided to Mr. East resulted in extreme discomfort and injury, in addition to negative attention to Mr. East, it is the carriers' position that they complied with section 149 of the ATR by accepting the service animal at no additional charge and by allowing the service animal to stay at Mr. East's seat for the duration of the flight.

[36] The Agency disagrees. The words used in section 149 of the ATR cannot be read in a vacuum. The words and the scheme of the impugned section must be considered.

[37] It goes without saying that in order for a level of accommodation to be appropriate, it must meet a basic standard of safety, such that the person is not exposed to unreasonable risk of injury. In the case of persons who are blind and travel with service animals, this principle is equally applicable to the service animals on which they rely for their mobility and independence, such that the conditions under which the service animal is transported should not negatively impact on its well-being and safety to the point that its ability to perform its functions and provide the assistance to the person with a disability may be compromised.

[38] The Agency recognizes that persons who are blind and travel with service animals generally share their space with their animals, which may cause some level of discomfort. However, the Agency is of the opinion that Mr. East's experience goes well beyond discomfort and significantly detracted from the appropriateness of the accommodation. Further, the Agency is of the opinion that extreme discomfort negatively impacts on a person's well-being, increases the risk of injury, and therefore has safety implications for the person. In addition, the Agency accepts Mr. East's position that where the space provided results in the service animal being forced to travel in a very constrained position, this has negative implications for the service animal which may impact on the animal's ability to function in the future, and the Agency is of the opinion that, given the critical role that service animals play in the mobility and independence of persons who are blind, the risk of injury to service animals is a significant safety-related concern for their owners.

[39] The carriers' interpretation could have the effect of denying the very right afforded to persons with disabilities to travel without charge with their certified service animals. This right cannot be limited solely or restricted to situations where the service animal can "fit" within the space allocated by the service provider. The Agency is aware that it is a carrier's decision to determine the aircraft types and configurations it will operate and that such decisions could lead to further changes in the future. The Agency notes Mr. East's comments in this regard, in that he is of the view that the carriers' changes in aircraft configuration have resulted in the reduction of space to the point that they are suggesting that he use a smaller service animal. The carriers' interpretation would lead to the absurd situation of placing an obligation on persons with disabilities to acquire a service animal capable of occupying the floor space as allocated by the carrier if they want to travel with their service animals without charge. Such an interpretation will annihilate the basic rights provided by section 149 of the ATR.

[40] It is a well-established principle of statutory interpretation that the legislator does not intend to produce unjust and incoherent consequences in the application of a regulation. If a legislator had intended to impose an obligation on the carrier only in instances where "space permits", it would have done so with statutory language that is both plain and familiar. For example, the legislator would have chosen language similar to that used in subsection 148(5) of the ATR which states that, with respect to the stowage of wheelchairs in the passenger cabin, "where space permits, an air carrier shall, without charge, permit a person..." Any like intent with respect to section 149 of the ATR would have been expressed in similar language.

[41] Additionally, the Agency finds the carriers' comment that "the person seeking the accommodation should be reasonably expected to equip himself with a service animal capable of occupying the floor space at the person's feet" to be unreasonable and uninformed. In response, Mr. East explains that he does not select his guide dog but rather it is selected by the Internationally Accredited Guide School for the Blind that has professional staff and trainers, who are also accredited. They choose a suitable match based on Mr. East's attributes. Mr. Ease states that he, therefore, does not have control as to the size of his dog. However, he reiterates that his guide dog is of average size. He submits that to suggest he should have a smaller dog is ludicrous. He states, "imagine me a six foot three inch fellow with a miniature poodle to guide me."

[42] Mr. East points out that he pays for a seat and all the room as any other customer. He submits that his guide dog should have enough space to lie down at his feet and this space should be in addition to the room for which he has paid.

[43] The Agency accepts Mr. East's submission that guide dogs are not chosen by persons with disabilities; rather, an accredited guide school for the blind has professional staff and trainers who choose a suitable match.

[44] Another limit to the Agency's interpretation raised by the carriers is concern with preserving the distinction between adjudicative and legislative functions. The carriers cite Canada (Attorney General) v. Consolidated Canadian Contractors Inc. (C.A.), [1998] F.C.J. No. 1394, where the Federal Court of Appeal considered whether it was appropriate for it to read in a "due diligence" defence into certain provisions in the Excise Act providing for penalties for GST underpayment. The carriers note that the Excise Act did not, on its face, provide a due diligence defence but the Court considered that at common law, it is a basic principle of fairness that a due diligence defence should be available. The carriers further note that the Court considered the so-called "golden rule" which is that legislation should be read contextually where a plain meaning approach would create an absurdity, which includes manifest unfairness (para. 28). However, the Court underlined that in undertaking a contextual approach, courts must be mindful of the line between making and applying law:

[O]ne cannot escape the fact that the exercise of judicial discretion through the interpretation of statutes has traditionally been a source of unease. The underlying fear is that the line to be drawn between interpretation and policy making will disappear, and that statutory interpretation will dissolve into judge-made law. This contravenes our understanding of parliamentary sovereignty in which validly enacted legislation is considered paramount to judge-made law and courts are obliged to defer to the legislature's public policy choices as expressed in the language of the statute: see Sullivan, supra, at page 25 (para. 29). (emphasis added)

[45] In this case, the carriers submit that in adopting such a broad interpretation of section 149 of the ATR, the Agency has effectively created additional regulations requiring a guarantee of sufficient space at the time of reservation, particularly through the provision of an additional seat to a person with a service animal. However, the Agency is not, in fact, creating additional regulations. Subsection 151(1) of the ATR states that when services set out in Part VII of the ATR, which includes section 149, are requested 48 hours in advance, the carrier must provide the person with the service. Given proper advance notice is provided, this regulation obliges an air carrier to provide certainty to a passenger with a disability that their request for a service set out in Part VII of the ATR will be accommodated. This is not related to an "expansive" interpretation of section 149 of the ATR, but rather to the requirements found in section 151 of the ATR.

[46] The Agency in its Show Cause Decision found that the carriers' ad hoc practice of assigning seats at time of departure resulted in the provision of insufficient space to Mr. East. As noted in the Show Cause Decision, while the Agency recognizes that the carriers accepted Mr. East's service animal for travel at no additional cost, the Agency found that a request for sufficient space should be dealt with at the time of reservation. Therefore, in its corrective measure the Agency directed the carriers to amend their procedures and ensure that at the time of reservation and, upon receipt of a request at least 48 hours prior to the scheduled flight departure, the carriers will provide certainty that the person will be assigned seating with sufficient floor space at no additional cost.

[47] The Agency confirms that it does not interpret section 149 of the ATR as requiring that an extra seat be provided without charge. As the Agency noted in the Show Cause Decision, in some cases the space available at the person's seat will be adequate to accommodate both the person and the person's service animal. However, there will be situations, as in Mr. East's case, where additional space is required due to (a) the configuration of the aircraft, (b) the size of the animal, (c) the duration of the flight, etc. In such situations, it is the carrier's decision to determine how it will comply with section 149 of the ATR. It may decide to provide additional seating, upgrade to a higher class of service, etc. However, to charge a fee for the means by which it provides the accommodation would constitute a contravention of subsection 149(1) of the ATR.

[48] Based on the above, the Agency rejects the carriers' argument that the Agency has incorrectly interpreted section 149 of the ATR. The Agency, therefore, finds that the carriers have not shown cause why they have not contravened section 149 of the ATR, nor why the obstacles are not undue. As such, the Agency finds that the carriers contravened section 149 of the ATR and that the following constituted undue obstacles to Mr. East's mobility:

• the floor space provided for Mr. East's service animal at the seat initially assigned to Mr. East and the difficulties he experienced upon boarding and before the commencement of Air Canada Flight No. AC137 as a result of the carriers' practice of attempting to provide accommodation at no additional cost to persons who travel with service animals for which the floor space at the assigned seat is insufficient; and,
• the floor space provided for Mr. East's service animal at the seat assigned to Mr. East on Air Canada Jazz Flight No. AC8576.

[49] In addition, in instances where the carriers choose to comply with section 149 of the ATR by way of providing the space available at the adjacent seat, the Agency finds that the carriers' policy to impose a fee for this accommodation constitutes a contravention of subsection 149(1) of the ATR.

[50] In their response, the carriers did not provide any specific arguments why the Agency should not require the carriers to implement the corrective measure set out in the Show Cause Decision. Therefore, the Agency concludes that the corrective measure set out in the Show Cause Decision is necessary to ensure compliance with subsections 149(1) and 149(2) of the ATR and, thereby, eliminate the undue obstacles experienced by Mr. East.

CONCLUSION

[51] Consequently, the Agency directs the carriers to, within 90 days from the date of this Decision, take the following corrective measure, as it applies to service animals described in subsections 149(1) and 149(2) of the ATR:

• Develop, in respect to their domestic flights, policies and procedures to ensure that at the time of reservation, and upon receipt of a request at least 48 hours prior to the scheduled flight departure, the carriers will provide certainty that the person will be assigned seating with sufficient floor space at no additional cost. In this way, the carriers have the flexibility of delaying the assignment of a specific seat(s), provided they guarantee that appropriate accommodation will be provided. The determination concerning the seating accommodation that will be provided shall be made:
  • through dialogue with the person with a disability travelling with a service animal;
  • by reference to the floor space available at seats within the aircraft for use by the person and the service animal; and
  • by reference to the amount of floor space needed to accommodate the service animal.

[52] These policies and procedure must also include provisions setting out that, where such a request is made less than 48 hours prior to departure, the air carrier will make a reasonable effort to provide the service.

[53] The Agency notes the carriers' comment that the Agency did not specify what measures the carriers must take to ensure that sufficient space is provided. As previously noted, carriers are free to use different means of providing the required accommodation and are best placed to know what space is available in the aircraft given their awareness of aircraft configurations, including any changes being planned in this regard. However, the Agency will engage in a consultative process, as it relates to subsection 2.6 of the Agency Code of Practice for Aircraft Accessibility for Persons with Disabilities to provide guidance to air carriers in terms of the floor space requirements for various-sized service animals.

Members

• Geoffrey C. Hare
• Beaton Tulk