Office of the Prime Minister
House of Commons
Ottawa, ON K1A 0A6

March 8, 2018
Dear Prime Minister Trudeau,

The Canadian Federation of the Blind noted with interest that the federal government is extending the Medical Expense Tax Credit to cover those with psychiatric service dogs. This is happening at the same time that funding from Veterans Affairs Canada is being used by the Canadian General Standards Board to create service dog standards that we believe are unnecessary, unreasonable, and antithetical to human rights. We are gravely concerned that the failed CGSB process will be allowed to continue and create devastating problems for blind people who work with guide dogs.

We fear that CGSB’s entirely inappropriate interference in the lives of guide dog users will be justified under the dubious guise of making sure that only “legitimate” psychiatric support dog owners are given a tax benefit.

CGSB is undoubtedly competent in setting standards for physical products. The agency has no experience, understanding, or respect for human rights matters. They have demonstrated unprofessionalism by failing to make their comment process accessible until forced to do so. They have demonstrated a profound lack of understanding of inclusive human rights processes by requiring non-disclosure agreements from participants in their working groups.

Guide dog teams have functioned successfully in Canada for nearly a hundred years without CGSB standards. The industry has policed itself; consumers and the general public overwhelmingly are happy with the results.

More and more individuals with disabilities are discovering ways in which partnering with well-trained dogs can enhance their lives. As is often the case with innovative ideas, time and experimentation will be required for concepts and practices involving these relatively new human/animal partnerships to mature. Unless rights holders who are the handlers of other service dogs demand otherwise, we strongly believe government should not interfere by rushing to create standards before service dog programs are fully developed.

Rolling back the clock on basic human rights for guide dog users because the service dog industry is still in development is unconscionable! Such homogenization represents the worst kind of “one size fits all” thinking. Claims that these standards are “voluntary” and that explanatory language in the form of a “companion document” will accompany them in no way mitigates the harm they will do.

We urge the VAC and Public Works Canada to cease all financial and other support for CGSB’s unwarranted interference in an area where its involvement is not appropriate and its actions have been incompetent and unprofessional.

Sincerely,

Mary Ellen Gabias, President
Canadian Federation of the Blind