Why DoT Should Allow Airlines to Limit the Number of Service Dogs On Board

Why DoT Should Allow Airlines to Limit the Number of Service Dogs On Board


The Department of Transportation Should Allow Airlines to limit the number of service dogs permitted on board a flight, due to safety. Some airlines already do this for pets, but unfortunately airlines are constrained by the DoT under the Air Carrier Access Act from limiting the number of service animals aboard (“Airlines cannot refuse to allow your service animal onboard because it makes other passengers or flight crew uncomfortable”) although airlines are allowed to refuse transportation to service animals that “exhibit aggressive behavior and that pose a direct threat to the health or safety of others.”

Hardly a week goes by without an airline incident, such as the severe turbulence that hit Singapore Airlines, leaving one dead and scores injured; Alaska Airlines flight 1282 where a door plug blew out mid-air; or the recent Southwest flights that came within 400 feet of the ocean off the coast of Kauai; a “Dutch roll” while en route to Oakland; and that dropped to 525 feet over an Oklahoma City neighborhood. Needless to say, these incidents pose a risk to everyone, passengers and crew, which can be exacerbated if there are numerous service dogs on board, especially ones with less training, which can interfere with the services of true service animals and contribute to chaos and impede evacuation.


Less Trained “Service Animals” Can Interfere With True Service Animals

Unfortunately, even after the DoT's regulations in January 2021 that banned Emotional Support Animals (ESAs) from flying as service animals, many passengers keen to take their dog with them without paying a pet fee learned to fill out forms and couch their animal as a “Psychiatric Support Animal,” which is still permitted. Many of these animals are relatively untrained, and beyond potential discomfort to other passengers, they pose a real threat to true service animals.

For example, Donald Overton Jr., executive director of the Blinded Veterans Association, reported that he lost the use of his guide dog, a German Shepherd named Pierce, who was trained for years at a cost of thousands of dollars. After Pierce was attacked multiple times by untrained “support” animals and pets on planes and in airports, the dog eventually became too reactive and anxious to continue working as a service animal. Per Overton, “In the blink of an eye, somebody who has just casually and carelessly decided that their pet should be out there can take all of that and destroy it.”


Why are People with Severe Dog Allergies Deprioritized Over Dogs and Their Owners?

Millions of Americans have a dog allergy, and 10-20 percent of people in the world are allergic to dogs. But contrary to the marketing claims, there is no such thing as a true hypoallergenic dog. Some dogs can elicit fewer allergy symptoms than others for some people, but dog dander is what causes allergy symptoms. Dander comes from the dog's saliva, skin cells, and urine. So unless your dog has no mouth, no skin, and doesn’t pee, it will release dander into the air, such that someone nearby with a dog allergy will suffer.

Yet there are multiple instances where passengers with dog allergies have been removed from a flight due to another passenger with a dog. Even if the passenger with the dog has a true disability and the dog is a true support dog, both passengers are protected under the Air Carrier Access Act (ACAA). “If a passenger has an allergy that rises to the level of a disability and there is an individual with a service animal seated nearby, airlines have an obligation to accommodate both passengers under the ACAA,” DOT rules say. “One disability does not trump another.”

With post-pandemic travel demand and fuller flights, it makes sense for there to be a limit on the total number of service dogs and pets on a given flight, so that both disabilities can be accommodated.


A Large Number of Service Animals Can Slow Down an Evacuation

The FAA requires that in the event of an emergency, an airplane must be able to be evacuated within 90 seconds. The problem? Current FAA tests, which only use people between the age of 18-60, fail to take into account real world conditions: children; elderly, obese, and disabled passengers; current seat density; significant carry-on luggage; and support dogs and pets. Consider, for example, the Japan Airlines A350 that burst into flames at Tokyo Haneda Airport after colliding with a Japanese Coast Guard plane, in January 2024. Remarkably, all 379 passengers and crew safely evacuated, having left their baggage behind as instructed. Paul Hayes, director of air safety at a UK-based aviation consultancy, said “it was a miracle that all the passengers got off [the plane in time].” He attributed the success to both the cabin crew doing an excellent job, and passengers obeying directives by not taking any hand luggage. It's also worth noting that JAL does not permit any pets in the cabin (they are required to be transported in the aircraft hold). While JAL does permit guide dogs with their disabled owners in the cabin, Japan only recognizes “mobility service dogs,” which support their owners' physical disabilities. Japan does not recognize other service animals that are used for psychological needs, and these are not certified as service animals in Japan.

Even with passengers not taking luggage or animals with them, the evacuation didn't take 90 seconds: it took 6 minutes to open the emergency exits, and a full 18 minutes from the moment of impact until the pilot left the plane, having ensured the safety of his crew and passengers.

Had this A350 been a U.S. plane with its typical mixture of passengers, including children, elderly, disabled, service animals, and pets, does anyone think that the evacuation would have been as cooperative or as successful? Getting hundreds of humans to help each other exit a burning aircraft within seconds is difficult and stressful enough, without adding on countless animals, some of whom are very poorly trained for emergency situations.

While flight emergencies and evacuations, thankfully, are still relatively rare, we need to protect the greater good (more passengers) by limiting the number of animals on board each flight.


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