The DOT's Proposed Emotional Support Animal Restrictions could result in a ban on Emotional Support Animals in airline cabins. Here's a summary of the key proposed changes, followed by how to comment on them.
- A Service Animal would be defined as a dog that is “individually trained to work or perform tasks for the benefit of a qualified individual with a disability, including a physical, sensory, psychiatric, intellectual or other mental disability.”
- Airlines would NOT be required to recognize emotional support animals as service animals, and could treat them as pets (hence requiring a fee for their transport)
- Airlines would be permitted to limit service animals to dogs
- Airlines would be permitted to require passengers to provide a complete US Department of Transportation Service Animal Air Transportation Health Form, Behavior and Training Form and Relief Form as a condition of flying
- Airlines would be permitted to limit the number of service animals traveling with a single passenger with a disability to two service animals and require that both service animals fit in their handler's lap and/or within their handler's foot space
- Airlines would be permitted to require that a service animal be harnessed, tethered, or otherwise under the control of its handler
How to Comment
Go to the Regulations.gov “Traveling by Air with Service Animals Notice of Proposed Rulemaking page and click on the blue “Comment Now” button to provide your comment.
Why The Proposed Changes Matter
As the proposed rules note, there's been a significant increase in animals flying in U.S. airline cabins, and along with that, the number of passenger complaints has also increased significantly, from 719 complaints made directly to U.S. and foreign airlines in 2013, to over 3000 such complaints in 2018.
Moreover, disabled passengers who rely on their support animals and disability advocates have voiced concern about untrained emotional support animals in the cabin distracting or interfering with trained support animals. There's good reason why many guide dogs have conspicuous signs on them asking passers-by not to pet or distract the dog, since its owner's life can depend on the service animal being focused on performing its job.
Additionally, many passengers are allergic to dogs, sometimes severely so (we have this allergy in my own family). Shouldn't a person's right to breathe be taken at least as seriously as a person's right to bring their support animal?
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