Submissions

To: Dunedin City Council
Date: July 2024

Purpose

This submission’s primary purpose is to ensure that while acknowledging the importance of dog control for safety, the policies do not inadvertently create barriers or misunderstandings for disabled people, particularly those who rely on disability assist dogs. The submission seeks to refine the proposed policies to better serve all community members, including disabled people, by advocating for clear language and public awareness initiatives regarding assistance animals and safe dog handling.

The submission also commends positive aspects of the policy, such as the recognition of Disability Assist Dogs and the waiver of their registration fees.Concurrently, DPA aims to recommend crucial improvements to ensure public safety and prevent unnecessary disturbances to service animals, particularly concerning the physical control of dogs and raising public awareness about working dogs.

Summary of DPA submission

DPA commends the Council for recognising Disability Assist Dogs as working dogs and for their proposal to continue not charging registration fees for these essential animals. This policy is seen as immensely beneficial, acknowledging that many disabled people live on low, fixed incomes and that maintaining assist dogs incurs high costs. DPA believes that retaining the no-fees policy reinforces the vital role that disability assist dogs play in supporting the independence, dignity, and inclusion of disabled individuals.
 
However, DPA identifies a key area for amendment within the Dog Control Policy, specifically concerning the provision that requires dog handlers to "be physically capable of controlling the dog". While fully acknowledging the paramount importance of controlling dogs for safety reasons, DPA recommends rewording this provision. The proposed rewording would emphasise the need for all people in control of dogs to exercise all reasonable skill and care and to always prioritise safety, rather than focusing on physical capability, as this term could create unintended barriers for disabled dog owners or handlers. This amendment seeks to ensure the policy is inclusive and reflects a broader understanding of control, which might involve various supports or alternative methods for disabled individuals.
 
Furthermore, DPA requests that the policy explicitly highlight that all disability assistance dogs are working dogs and calls for the Council to collaborate with disabled people to run regular public awareness campaigns on this matter.
 
The submission implicitly advocates for policies that promote safety and accessibility for all pedestrians, including disabled people, parents with children, and autistic/neurodiverse individuals who may be distressed by unleashed dogs. By recommending clearer wording and public awareness, DPA aims to create a more inclusive and safer environment, reflecting their overarching commitment to systemic change for the equity of disabled people.
 
Key Recommendation:
DPA recommends that the Council re-word the Dog Control Policy to emphasise the need for all dog owners and handlers to exercise all reasonable skill and care and to always prioritise safety when handling dogs, rather than focusing solely on physical capability.
 
Supporting Statement 1:
This re-wording would better accommodate disabled people who may face challenges with a literal interpretation of "physically capable" but can still safely control their dogs through various means or supports.
 
Supporting Statement 2:
It ensures that the policy remains focused on the outcome of safety for all community members, including disabled people who might be affected by unleashed dogs, without creating an exclusionary criterion for dog ownership or handling based on impairment.