Continental sure has a lot of skeptical employees when it comes to customers with disabilities. Jessica tried to buy a ticket yesterday and was told no, because the ticket agent didn’t believe that Jessica’s self-trained service dog was legit.

I contacted Continental on 8/17/10 and had a 27 minute conversation with a woman was incredibly unhelpful.

I told them I have an owner-trained service dog and am planning on purchasing a ticket for a flight. The woman asked if it was a pet, and I said no. She asked what kind of service animal it is, and I said a dog. She said that was not what she was asking, and further explained she wanted to know what he does. I said he provides mobility assistance and listed his tasks of providing balance assistance and retrieving items. He does several other tasks but it is my understanding that I don’t have to list each one.

At that point, she asked me to send them a certification. I spent several minutes doing a back-and-forth about the fact that the federal law recognizes owner trained service dogs, and there IS no national certification. I explained several times that I trained him and he has completed public access training. Eventually, seeing how it was not going anywhere, I asked to speak to a complaint resolution officer, and she said I couldn’t without buying a ticket.

I explained how I felt they were denying access based on the fact that he did not come to a school.

At one point this conversation ensued. She said “Ma’am is this a pet” I said “No, he is a service animal”. She then replied “You have not provided enough evidence, so we are able to request documentation”.

I find it flawed that based on my factual answers to the two questions regarding whether he is a service dog and what tasks he does, they can declare that not enough information.

I asked several times exactly what kind of documentation they would like. After her replying over and over that I needed a certification, I said that was impossible because it did not exist, and could she help me with alternative documentation. She said to fax my documentation to a number, but could not provide any more information on what they would like as documentation, repeatedly stating that the documentation comes from the schools or companies that train the dog.

I feel this situation was not handled appropriately and the airline immediately denied us access based on the fact that my service animal is owner trained.

As far as I can tell, the DOT’s “Nondiscrimination on the Basis of Disability in Air Travel” rules (PDF) don’t say you have to disclose to an airline that you have a disability or use a service animal when you buy a ticket, just before you take the flight (see page 79). In some cases you must give at least 48 hours notice before your flight’s departure so the airline can prepare, and you may be asked to show up an hour earlier than other passengers.

My reason for bringing this up is because the official rules for verifying service animals seem to apply specifically to passengers boarding a plane, not potential customers fighting with a hostile, and possibly untrained, ticket agent over the phone.

For example, the rules state that the airline employee should try to verify based on a visual assessment as well as simple questions, which is impossible over the phone. Also, the employee has is strongly advised to contact a complaint resolution officer if you disagree with her assessment; you should not even have to ask for this.

So let’s assume you bought your ticket, showed up with your service animal, and then ran into this same suspicious employee. Here’s what the rules say:

For service animals trained to provide emotional or psychiatric support, airlines can ask for documentation. For all other service animals, they’re supposed to attempt in good faith to determine whether the label fits by asking questions and making direct observations. Employees are supposed to understand that not all service animals come with fancy certificates (page 101):

There may be cases in which a passenger with a disability has personally trained an animal to perform a specific function (e.g., seizure alert). Such an animal may not have been trained through a formal training program (e.g., a “school” for service animals). If the passenger can provide a reasonable explanation of how the animal was trained or how it performs the function for which it is being used, this can constitute a “credible verbal assurance” that the animal has been trained to perform a function for the passenger.

The third part of the verification process (page 102) may be instructive to you and others with disabilities who have uncertified service animals:

3. Request documentation for service animals other than emotional support or psychiatric service animals: The law allows airline personnel to ask for documentation as a means of verifying that the animal is a service animal, but DOT’s rules tell carriers not to require documentation as a condition for permitting an individual to travel with his or her service animal in the cabin unless a passenger’s verbal assurance is not credible. In that case, the airline may require documentation as a condition for allowing the animal to travel in the cabin. This should be an infrequent situation. The purpose of documentation is to substantiate the passenger’s disability-related need for the animal’s accompaniment, which the airline may require as a condition to permit the animal to travel in the cabin. Examples of documentation include a letter from a licensed professional treating the passenger’s condition (e.g., physician, mental health professional, vocational case manager, etc.)

In other words, the rules leave a huge loophole that any airline employee can use to deny your request if all you offer is verbal assurance. On the other hand, something as simple as a note from your doctor will work–in this, the Continental employee was flat out wrong by saying the proof had to come from a training school. For animals providing emotional or psychiatric support, the rules say the letter should be no more than one year old, so I’d stick with that for any other animals as well just to be on the safe side.

Jessica added that she called United and was able to buy a ticket without any problems or harassment. Still, I recommend that you download the rules and familiarize yourself with them before you show up for your flight, just so you know how the rules protect you and what you’re required to provide.

Part 382, Passengers with Disabilities [DOT]

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