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Feedback Fridays

By Brig. Gen. Laura L. Lenderman | 502d Air Base Wing Commander | June 7, 2019

JOINT BASE SAN ANTONIO, Texas —

Feedback Fridays is a weekly forum that aims to connect the 502d Air Base Wing with members of the Joint Base San Antonio community. Questions are collected during commander’s calls, town hall meetings and throughout the week.

If you have a question or concern, please send an email to RandolphPublicAffairs@us.af.mil using the subject line “Feedback Fridays.” Questions will be further researched and published as information becomes available.

Installation & Facilities

Q. Why was the order of flags along the main road at Joint Base San Antonio-Randolph changed from when each state entered the Union to a seemingly random order?

A. You’re absolutely right that the flags are supposed to be in the order of when the states joined the union. Thank you for bringing this to our attention.

A few weeks ago a group of volunteers helped our JBSA-Randolph Executive Agent team replace the flags, which were beginning to fray. As the new flags went up, the order must have become jumbled and we apologize for the mistake.

The good news is that JBSA Proud Week is right around the corner (June 10-14). This will be a perfect opportunity for us to re-sequence the flags and get everything back the way it is supposed to be. Thank you again for your attention to detail and for informing us quickly!

Miscellaneous

Q. When vehicles go out of service to get monthly inspections done, why does it take all day if not two days to get the vehicles back?

A. Thank you for your question on routine vehicle maintenance repair time. The 502nd Logistics Readiness Squadron Vehicle Maintenance Team’s goal is to provide JBSA with safe and reliable vehicles in a timely manner to enable our customers to support their mission sets.

We maintain more than 2,000 vehicles across JBSA. To ensure safety, we give each vehicle a front to back inspection during routine visits. At times, unexpected repairs are discovered and per Air Force Instructions, we must address these issues which can drive additional customer wait time.
We cannot afford to compromise safety and want to make sure that every vehicle we service is kept at the highest standards of reliability. If extra time is required, your Vehicle Control Officer will be notified.

For general purpose vehicles, often times a temporary loaner can be checked out from the LRS Vehicle Operations Fleet located on each JBSA operation location. Thank you again for your question and patience.

Q. Will it ever be possible to be able to conceal carry on base?

A. Thank you for your question. As the Installation Commander, I am carefully considering this matter.

Security is my top priority. Not just at the gates, but for every person everywhere they go on JBSA. Restricting firearms carry to our Security Forces gives our Defenders an important advantage over anyone who means us harm, and provides confidence to our diverse population that they can move freely and safely while on base.

However, I've asked our Security Forces Group to develop options which could allow limited Law Enforcement Officers Safety Act (LEOSA) arming on-base.

However, the current discussion surrounds qualified law enforcement officer provisions and has not been expanded to Texas License to Carry authorities for non-law enforcement affiliated individuals yet.

Due to the unique construct of JBSA and its vast amount of mission partners and sister service residents, this is not a simple issue to resolve and not one that should be decided by only one command.

While I am confident there will be guidance provided regarding this topic in the not too distant future, it is incumbent upon us to address this issue with our sister service commanders to ensure their opinions and concerns are weighed into my ultimate decision.

Follow Up Q&A

I recently received a few follow up questions to a previous Q&A issued on 17 May regarding service dogs.

Original Question:
“Q. What is the Air Force or Department of Defense policy for service dogs at work and on base? Are there any requirements or documentation needed for a service dog to accompany an employee to work and base facilities? Where can I find this guidance?”

Original Response:
“A. Very good question. Service dogs generally must be allowed to accompany their handler into installation facilities that are considered public or unrestricted. For civilians and military members having a medical condition requiring the assistance of a service dog to do work or perform tasks for the benefit of the individual’s disability, service dogs generally are also allowed with approval from their chain of command.

Members may be asked to provide medical documentation if the need for the service dog is not apparent or known. For civilian employees who ask to bring a service dog as a reasonable accommodation, supervisors should engage in deliberative discussions with the employee and grant the accommodation if it assists the employee in doing the job, unless doing so would pose an undue hardship. We have granted this accommodation in several places across JBSA.

In addition to medical documentation, the supervisor is entitled to inquire as to what service the dog performs for the disabled employee.

If you’d like additional guidance, please see: Air Force Instruction 36-205, Affirmative Employment Program, Special Emphasis Programs and Reasonable Accommodation Policy; Air Force Instruction 34-1101, Warrior and Survivor Care; Department of Defense Instruction 1300.27, Guidance on the Use of Service Dogs by Service Members; and Air Force Guidance Memorandum to AFI 32-6001, Family Housing Management.”

I’ve provided clarifying guidance below, but please don’t hesitate to reach out, if anyone needs additional information. 

A service dog is any dog that is individually trained to do work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability.

Individuals with disabilities can bring their service dog into all areas of public facilities and private businesses where members of the public, program participants, clients, customers, patrons, or invitees are allowed.

A service animal can be excluded from a facility if its presence interferes with legitimate safety requirements of the facility (e.g., from a surgery or burn unit in a hospital in which a sterile field is required).

A public entity or a private business may ask an individual with a disability to remove a service dog if the dog is not housebroken or is out of control and the individual is not able to control it.

A service dog must have a harness, leash or other tether, unless the handler is unable to use a tether because of a disability or the use of a tether would interfere with the service dog's ability to safely perform its work or tasks.

In these cases, the service dog must be under the handler's control through voice commands, hand signals, or other effective means. If a service dog is excluded, the individual with a disability must still be offered the opportunity to obtain goods, services, and accommodations without having the service dog on the premises.

Individuals with disabilities cannot be refused access to a facility based solely on the breed of their service dog.

With respect to service animals, the Department of Justice has adopted a distinct policy under Titles II and III of the ADA that streamlines the process for responding to requests for service animals by limiting the types of inquiries that may be made and the documentation that may be required.

These limitations apply to the Air Force as a provider of public accommodations (such as base restaurants, temporary lodging, and shopping) and to any entity providing services to or for the Air Force. The rule for asking for information concerning accommodation requests at work by an
employee or applicant is different, and covered below: 

- A recipient of DOD funds or DOD Component may not deny a reasonable accommodation or reasonable modification request because staff is uncertain whether or not the individual seeking the
accommodation/modification has a disability or a disability-related need for an assistance animal.

- Recipients and DOD Components may ask individuals who have disabilities that are not readily apparent or known to the recipient or DOD Component to submit reliable documentation of a disability and their disability-related need for an assistance animal.

- To determine if an animal is a service animal, a public entity or a private business may ask two questions:
  . Is this animal required because of a disability?
  . What work or task has this animal been trained to perform?

The Air Force Guidance Memorandum to AFI 32-6001, Family Housing Management provides policy and procedures for the use of service dogs by Service members. It is DOD policy that:
. Recovering Service members (RSMs) who have medical conditions that require the assistance of a service dog for activities of daily living may utilize service dogs on DOD installations while on active duty.
. The Military Departments retain authority over installation access, control, and domiciling for all animals other than service dogs, including pets, therapy animals, and service dogs in training.
. Use of animal-assisted therapy and animal-assisted activities will be in accordance with policies of the Military Departments and are not covered by this instruction.
. Military working dogs adopted by Service members in accordance with section 2583 of Title 10, United States Code (Reference (d)) and any dogs not obtained from an accredited service dog organization approved by the U.S. Department of Veterans Affairs do not meet the qualifications for service dogs as defined in Code of Federal Regulations noted (Section 35.136 of Title 28, Code of Federal Regulations (CFR) (Reference (b), Service Animals, and Section 17.148 of Title 38, CFR (Reference (c), Service Dogs).

References:
 - DODI 1300.27 Guidance on the Use of Service Dogs by Service Members, Jan. 7, 2016
- Department of Justice, Americans with Disabilities Act Title III Regulations, Sept. 15, 2010
- AFI 36-205, Affirmative Employment Program (AEP), Special Emphasis Programs (SEPS) and Reasonable Accommodation Policy (Chapter 8), 1 December 2016
- Department of Justice, Civil Rights Division, Frequently Asked Questions about Service Animals and the ADA SouthwestADA.org
- https://www.opm.gov/faqs/QA.aspx?fid=de14aff4-4f77-4e17-afaa-fa109430fc7b&pid=78a37c1f-6955-4576-afb6-943aa22a36a8
- https://www.ada.gov/regs2010/service_animal_qa.pdf
- https://www.nps.gov/deto/planyourvisit/upload/Service-Animal-Policy-DOJ.pdf
- http://ada.gov/
- www.askjan.org
- www.odep@dol.gov