ursine1

I'm surprised. If you did, it would be obvious that the proposed changes are timid and only a tiny step towards limiting "fake" ESAs.

Lets look at the proposed rule changes. My comments follow each proposal.

• (1) treating psychiatric service animals similar to other service animals; [This would make it easier to fly with PSAs, not harder.]
  
• (2) distinguishing between emotional support animals and other service animals; [This is actually now already the case functionally.]

• (3) requiring emotional support animals to travel in pet carriers for the duration of the flight; [Positive. This is a new change that would be welcomed by those wanting more restrictions on ESAs.]
  
• (4) limiting the species of service animals and emotional support animals that airlines are required to transport; [Carriers already do this. This would codify it into law.]
  
• (5) limiting the number of service animals/emotional support animals required to be transported per passenger; [Assuming that limit becomes 1 (from 3) I don’t see this as a very harsh change, or one that would affect many passengers with PSAs/ESAs.]
  
• (6) requiring service animal and emotional support animal users confirm that their animal has been trained to behave in a public setting; [While this sounds like a positive change, the rule would not require that the animals be trained, but that the passenger confirm that the animal is trained. Those are two very different things.]
  
• (7) requiring service animals and emotional support animals have a harness, leash, or other tether with narrow exceptions; [A positive but minor change, that presents only a small hurdle to those with ESAs.]
  
• (8) limiting the size of emotional support animals or other service animals that travel in the cabin and the potential impact of such a limitation; [Another potentially positive change, but one that would affect only a small number of those traveling with ESAs.]
  
• (9) prohibiting airlines from requiring a veterinary health form or immunization record from service animal users without an individualized assessment that the animal would pose a direct threat to the health or safety of others or would cause a significant disruption in the aircraft cabin; and [This is a limitation on carriers that would be a negative change and hurt efforts to restrict ESAs.]
  
• (10) no longer holding U.S. airlines responsible if a passenger traveling under the U.S. carrier’s code is only allowed to travel with a service dog on a flight operated by its foreign code share partner. [Irrelevant to the ESA discussion.]

There are a couple positives here, but as I suggested earlier, they're pretty small efforts. The text of the Interim Statement of Enforcement Priorities Regarding Service Animals (posted earlier) gives some deeper insight into the DOT's position, as they balance the interests of air carriers, passengers and the disabled. Take a look.