Well, it is largely specific to service dogs called out in Title II. Certainly the structure and purpose of what modifications or accommodations are for, and why and how public entities should meet them in order to provide equal opportunity and access for the individual disability under ADA has some applicability. There are no such specific call outs to LTFA under Title II but ADA AA is non-specific on qualifying condition, and we know satisfying one statute does not automatically mean all are satisfied for the purposes of delivering FAPE thanks to Tustin.
In my non-lawyer opinion. Of course, the judiciary branch may not agree all that much with executive or administrative law. Not to mention the generous exemptions for DOT and religious entities who are not recipients running private schools.
But this statement was in response to public education school boards responsibility to meet needs with the student's choice as a factor not unilaterally by the school through a narrow interpretation of reasonable. Sounds familiar.
Service dogs do tend to be one of those categories of 'impact on other students' accommodations written alongside food allergy accommodations in COSA literature. Those dots have been connected before by NSBA's legal arm.
Citing my source. I can put an APA cite if desired. It covers service dogs and peanut allergy. Note how in this COSA document it's framed as "beyond inclusion." Very different from the Statement of Interest issued.
Abstract:
This paper provides suggestions for dealing with issues beyond the inclusion of students with disabilities, such as accommodating students with severe allergies or behavioral problems in general classes.