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The DOT Wants YOU to Weigh In on What Is (& Isn’t) a Service Animal

The DOT Wants YOU to Weigh In on What Is (& Isn’t) a Service Animal
Joe Cortez

The U.S. Department of Transportation wants flyers to weigh in on a proposed change which would limit the scope of “service animal” aboard commercial aircraft. The suggested amendment to the Air Carrier Access Act would prohibit “emotional support animals” from flying as service animals and create stricter rules and documentation for those who wish to fly with their duly-trained animals.

The U.S. Department of Transportation (DOT) wants your opinion on changes to service animal rules, as they look to add stricter requirements to which four-legged companions can fly in the main cabin. The “Notice of Proposed Rulemaking” was announced on Wednesday, Jan. 22, with comments open for the next 60 days. Interested flyers can submit a comment about the changes to the DOT at, under docket number DOT-OST-2018-0068.


Proposed Changes to the Air Carrier Access Act

Under the current definition provided under the Air Carrier Access Act, a “service animal” is: “Any animal that is individually trained or able to provide assistance to a person with a disability; or any animal that assists persons with disabilities by providing emotional support.” Some flyers attempted to take the definition to the extreme, attempting to board flights with pigs and even a peacock.

The proposed DOT changes would severely limit who could fly with a “service animal,” and under what conditions. If approved, the changes would create two clear criteria for when an animal can fly as a service companion:

  • Service animals would be limited to “A dog that is individually trained to do work or perform tasks for the benefit of a person with a disability.”
  • “Emotional support animals” would no longer qualify to fly under the “service animal” definition.

The rule changes would allow force airlines to adopt DOT forms verifying the health, behavior, and training for a service animal. In addition, those flying with verified service animals would be forced to arrive at the airport at least one hour in advance of their flight time to “process the service animal documentation and observe the animals.”

However, the rule change falls short of banning any specific breed from the cabin. If adopted, airlines would be prohibited from “refusing to transport a service animal solely on the basis of breed.” But if that same animal displays aggressive or threatening behavior, the airline reserves the right to refuse transportation.


The Current Problem With Support Animals

The proposed changes come after a number of noted incidents over the past two years from “emotional support animals.” In Feb. 2019, an emotional support dog attacked a five-year-old girl at Portland International Airport, while an American Airlines flight attendant was bitten by a service animal on a July 2019 flight. According to veterinarians who spoke to FlyerTalk, emotional support animals are not necessarily trained to handle the stress of flying, resulting in misdirected acts of fear or aggression.

As “emotional support animals” became more popular, some groups expressed frustration with the current state of affairs. In Nov. 2019, over 80 organizations, including Leashes for Valor and the Association of Flight Attendants, signed a joint letter calling on the DOT to make changes.

While the rules were first drafted in Fall 2019, the public notice phase brings them closer to adoption. After receiving flyer feedback, the DOT will make a final decision on the change in the near future.

View Comments (19)


  1. alangore


    January 27, 2020 at 5:17 pm

    Service monkeys do exist, for people whose handicap prevents them from reaching for common objects. What’s needed is a uniform registration system and “federal license plate” for service animals.

  2. FlyingNone

    January 27, 2020 at 6:18 pm

    Simple – a seeing eye/ guide DOG for BLIND or DEAF or an AMPUTEE or PARALYZED person in a wheelchair who otherwise can’t walk or fully function for themselves. Cats, birds, gerbils, squirrels, etc cannot do that.
    People who are nervous, emotional, psychologically disturbed, psychotic, ADHD should be traveling with other humans.

  3. moeve

    January 28, 2020 at 1:42 am

    Find way to fly pets around without killing them at an acceptable price so this nonsense stops

  4. fotographer

    January 28, 2020 at 5:05 am

    aside from the real service dogs..
    it should no pets allowed.. if you need emotional support when you fly…dont fly
    when I had a cat.. and traveled, I saw no need to bring her with me…

  5. rcalabre

    January 29, 2020 at 5:06 am

    What many travelers with service cats, dogs, birds and pigs fail to recognize is the impact on other travelers. A few years ago on Southwest a flight attendant announced there would be no peanuts because someone had a severe allergy. While the lady across the isle had her emotional support mutt (no offense intended I don’t remember the breed) sitting on the seat next to her. On a different flight on American a woman with her emotional support cat had it on her lap and she was petting it. Hair was everywhere and we all know how well those seats are cleaned between flights. So a person with allergies is impacted even though there are no animals on their flight. For some it is a real problem. So, #1. These animals need real certified training from an approved training facility and they require observation, as suggested in the upcoming changes. #2. The animals must stay on the floor. No matter how well trained animals should never be on the seats. and #3. If any passenger or airline employee feels threatened while in flight the animal must be restricted to an area away from passengers or employees.

  6. 1readyset2go

    January 29, 2020 at 5:40 am

    If you are that nervous that you need an emotional support animal perhaps its time to visit a psychiatrist and get some talk about it and perhaps valium for your flight if the doctor thinks its that bad.

  7. broston

    January 29, 2020 at 6:00 am

    I’d like to see this rule adopted in my neighborhood supermarkets where every dog within eight blocks has suddenly become an emotional support animal when it’s convenient for the dog owner.

  8. Loren Pechtel

    January 29, 2020 at 7:46 am

    I don’t care the species, what’s important is the level of training of the animal. Anything trained to service animal standards should be fine. Emotional support animals do not have that training. Service monkeys do exist and I see no reason they should be banned.

  9. drphun

    January 29, 2020 at 8:20 am

    How about accrediting the training organizations, and then penalties and damages for fraudulent animals?

  10. Disneymkvii

    January 29, 2020 at 8:22 am

    Realistically, these people don’t need the ESAs. Most of these are just pets. Pets that the owners are too irresponsible to find a sitter for so they take them everywhere. I wish the practice would end, but it won’t Everyone is a victim. Everyone is special. My ESA is more important that your right to travel without stress from strange animals. My LGBTQESA identity means I’m allowed to do WHATEVER I WANT!

  11. wrfrhiannon

    January 29, 2020 at 8:42 am

    Crated animals should still be allowed to fly in the cabin.
    I agree with moeve, if the airlines would stop treating pets like suitcases, no one would be tempted to take a pet in the cabin. The airlines need to train their personnel better in how to safely accommodate pets in the holding areas before and after the flight and in the cargo hold. Or better yet, provide a pressurized, climate controlled area, as KLM does for horses. Yes, it’s pricey. But it is very safe with attendants flying with the animals. But what price do you put on the cost losing your pet?

  12. PointsPanda

    January 29, 2020 at 1:26 pm

    About time. I travel quite a bit between Mexico and the US with my dog and always had to be clear of the rules and regulations and pay the fee. I’ve always been tempted to register my dog as an “emotional support” animal but felt it would be wrong to do so because it makes people who have legitimate service animals looks bad. About time they close this loophole and make everyone who doesn’t have a service animal pay up.

  13. snidely

    January 29, 2020 at 1:49 pm

    We all know half these people are not psycho disturbed — just carrying a pet.
    You need a “handicap” sticker to park in a blue zone. I don’t think most of these “normal” people would want to be registered as “psycho deficient” and need an animal that would have to pass a test. BTW – why not require muzzles on dogs.

  14. CEB

    January 29, 2020 at 4:53 pm

    First, some will always find a way to abuse the system. Thus the question here is “how much abuse will be tolerated?” Clearly under today’s rules it has gotten waaaay out of hand, so something must be done.

    Second, what KIND of disabilities really require taking an animal with one? I’m sure there will be plenty of opinions here, but I would think seeing eye dogs are pretty obvious. But how does an animal service someone in a wheel chair? I do not think they can push the wheel chair, so I have a bit of a problem with that one. And service monkey’s, what do they do? Getting things down from high places is not a requirement when one travels IMHO. And if you open the door to monkeys, then what about “seeing eye” cats or pigs, which to my knowledge do not exist? Or talking parrots to help people communicate. You can see where I’m going with this, if you broaden the scope even a tiny bit you end up with all sorts of arguments about what is or isn’t a service animal of some sort and what is or isn’t a travel disability. There are many disabilities that impact lives, but a large number of them have nothing to do with travel. So how do we sort?

    Third, while I am allergic to cats and therefore would prefer they not be in the cabin, I certainly can tolerate the number of cats that would be on airplanes if people have to pay to bring them with them. The cost will severely limit the number on board airplanes. The question then becomes what other animals and what size of animals will be allowed in the cabin? Simplest to just prohibit all but service animals from the cabin, but this is not very palatable and I would not really support it either. So there certainly needs to be a discussion on this. Personally, I would probably come down on the side of a size limit in the range of the same as the supposed weight limit for carry on bags, typically 10 lbs. on LCCs and 15-20 lbs. on the majors. Plenty of room for discussion and argument here, but I do not see another way to control things than with a weight limit. And just to throw gas on the fire, what about someone traveling with their pet chicken from Wuhan China? Today!! Crazy, I know. But the reality is that one must consider a lot of different possibilities when making rules.

    Fourth, I find the spurious remarks about airlines and their handling of pets ridiculous. Are there occasional issues, certainly. But the reality is that 99.99 % of pets that travel in the cargo hold get to their destination just fine. Far more people have died in planes than pets. So let’s stay focused on the real issues and not get distracted with absurdities.

  15. EPtraveler

    January 29, 2020 at 7:19 pm

    I have a lifetime of 7 million miles. I’ve seen it all. I was on a JFK flight and there were 5 dogs. That is NOT safe. The way DOT has allowed airlines to put so many more seats on a plane and make everything so close together, they cannot have dogs on the floor in your row. Even getting out of your row to go to the bathroom is a big deal and with a dog on the floor it’s just not safe if we have to get out quickly. I agree with Flying None above, if you have a psychological disorder maybe you need to fly with another human. Makes more sense. It is completely out of control and DOT really needs to get a handle on this. It’s a workplace for FA and pilots. And, it jeopardizes everyone’s safety.

  16. Dalo

    January 30, 2020 at 1:45 am

    Seeing eye dogs only.

  17. SpudOz

    February 2, 2020 at 1:52 am

    Thank God Australia does not put up with this crap. Certified service dogs only allowed to travel on aircraft.

  18. Brian-AAFlyer

    February 2, 2020 at 3:59 am

    Interestingly, the DOT rules aren’t compatible with the ADA, the ADA lists two animals that can be used, Dogs and Minature Horses.. By denying the Minis on flights, you’d be violating the ADA.. as odd as that may be.. Don’t believe me, go check it out :)

  19. moeve

    February 3, 2020 at 7:47 am

    @CEB the Problem is that many airlines simply do not fly pets anymore due to the issues. Best example was the soldier and his family who were posted to Japan and took their dog. 2 years later wenn being transferred back to CONUS there was no way to get the bigger dog back because Delta no longer accepted animals for the hold. As I said – find a way to do it safely and most of all at a reasonable price and most pet owners will be responsible. However if it is way too expensive or simply not possible there will be tooo many to „use“ this only option. I have transferred intercontinentally with pets before but I would truely hate to have to do it nowadays.

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