If you feel that way, then lobby Congress to change the law or the FAA to modify the correspondig CFR (I don't recall the exact interplay of the ACAA and the FAA's CFR with respect to ESAs).
I don't need to. It already exists:
14 CFR Part 382
With respect to an animal
used for emotional support (which need not
have specific training for that function),
airline personnel may require current
documentation (i.e., not more than one year
old) on letterhead from a mental health
professional stating (1) that the passenger has
a mental health-related disability; (2) that
having the animal accompany the passenger
is necessary to the passenger’s mental health
or treatment or to assist the passenger (with
his or her disability); and (3) that the
individual providing the assessment of the
passenger is a licensed mental health professional
and the passenger is under his or her professional care.
Airline personnel
may require this documentation as a
condition of permitting the animal to
accompany the passenger in the cabin. The
purpose of this provision is to prevent abuse
by passengers that do not have a medical
need for an emotional support animal and to
ensure that passengers who have a legitimate
need for emotional support animals are
permitted to travel with their service animals
on the aircraft. Airlines are not permitted to
require the documentation to specify the type
of mental health disability, e.g., panic
attacks.
TWO animals for emotional support? That is not in the regs and is a clear sign the animals are pets. In the hold they go and I hope the passenger is placed in a middle seat in the last row of the plane.