Flying with Emotional Support Animals, Service Animals and Therapy Animals

What is a Service Animal?

Service animals are offered protections under the Americans with Disabilities Act. For years, there was confusion as to what a service animal was as the definition under 14 CFR Part 382 (Part 382) were vague. Soon, all sorts of animals were entitled rights under this regulation including ducks, peacocks, pigs and more.

In December of 2020, the US Department of Transportation (DOT) passed an amendment defining a service animal as a dog that "individually trained to do work or perform tasks for the benefit of a qualified individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability."

Under this amendment, service dogs must perform at least one of the daily functions and tasks that the individual with a disability cannot perform for themselves.

"Seeing eye dogs" are one type of service animal, used by some individuals who are blind. This is the type of service animal with which most people are familiar. But there are service animals that assist persons with other kinds of disabilities in their day-to-day activities. Some examples include:

Alerting persons with hearing impairments to sounds.

Pulling wheelchairs or carrying and picking up things for persons with mobility impairments.

Assisting persons with mobility impairments with balance.

Alerting persons as to the onset of seizures.

Service animals rights are protected by the Americans with Disabilities Act (ADA) which states that they must be permitted into any privately owned business in the United States that serves the public, such as restaurants, hotels, retail stores, taxicabs, theaters, concert halls, and sports facilities, and government buildings. Private owners are prohibited from discriminating against individuals with disabilities.

It is not required that documentation be shown to support a service dog; however, businesses and airlines may ask whether the service dog is accompanying the person due to a disability and what task they perform to assist their owner. It is always recommended (and sometimes required), that service dogs wear vests or other identification and also be leashed when in public.

Service dogs that are utilizing commercial airlines for travel are also protected under the Air Carrier Access Act (ACAA), and the United States Department of Transportation (DOT).

Because they are protected under the ACAA, service dogs, the ACAA states that the airlines cannot refuse to allow service onboard because they make other passengers or flight crew uncomfortable. (including those with allergies)

Because they are trained to provide services that help those with physical disabilities, they may accompany the people they serve in places where other animals would not be permitted such as in the cabin of an aircraft even when they exceed normal carry-on requirements. In every case, they are elgible to fly without any charges incurred. Additionally, there may be restrictions if the service dog is recognized as a dangerous breed.

Dogs are the only animals that are legally recognized as service animals under the ACAA after an amendment to DOT 14 CFR Part 382 (Part 382) passed in December, 2020 which defines a service animal as a dog that is "individually trained to do work or perform tasks for the benefit of a qualified individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability".

All dogs providing assistance to their owners must behave properly around other people or animals. When flying, they must not impede cabin operations and their size must allow them to fly without affecting other passengers.

Dogs must be socialized, be mannerly, and show no signs of aggression to other passengers or cabin crew.

Service dogs must be trained to perform an identifiable and necessary task for their handlers. They should provide this service consistently and not be distracted by other activity around them.

Service dogs must have an even temperment and remain calm and focused on serving their passenger.

Emotional Support or Comfort Animals

Emotional support or comfort animals are pets that provide support for their owner for mental disabilities defined in the Diagnostic and Statistical Manual of Mental Disorders. Research suggests that people with psychiatric disabilities can benefit significantly from comfort animals. ESAs have been proven extremely effective at addressing the symptoms of these disabilities, such as depression and post-traumatic stress disorder, by providing therapeutic nurture and support.

An emotional support animal (ESA) no longer qualifies for protection under the Air Carrier Access Act (ACAA). However, if their owner can provide certification from a treating licensed medical professional that their dog is trained to perform a task that is necessary for the owner's benefit, the airline can consider accepting the dog as a service dog. In these cases, the decision is up to the discretion of the airlines.

Related: more information on what you should consider when selecting a dog to be an emotional support animal.

All owners of service dogs should notify their airline in advance that they are traveling with an assistance animal. Many airlines will require additional documentation such as DOT forms. More information can be found regarding airline pet policies for service and emotional support animals.

Therapy Animals

Therapy animals are used in Animal Assisted Therapy to improve the physical, social, emotional and cognitive condition of the patient. A therapy animal is normally a dog that has been obedience trained and screened for its ability to interact favorably with humans and other animals. The primary purpose of a therapy dog is to visit people in hospitals, care homes and retirement centers who enjoy being visited by a friendly dog. They are generally handled by volunteers who both train the animals and then take them on visits.

In almost all cases, therapy animals are not afforded protection under the Air Carrier Access Act.

Service Animals in Training

Service animals being trained to assist people with disabilities are not under ADA protection until their training is complete. Some airlines such as KLM and Allegiant will accept service animals in training if they are traveling with their trainer and the trainer must provide a letter written on the training school's letterhead stating "the animal is training to assist a person with a disability". Animals being transported to their new owner without a trainer DO NOT qualify for ACAA protection.

Flying with a service or comfort animal

When you fly with service animals, almost all airlines will permit your service animal to fly with you in the cabin, even if your destination country requires live animals to enter in the cargo hold. Airline pet policies for US-based airlines or those originating from or terminating in the US are basically similar because these airlines are subject to ADA, ACAA and DOT regulations.

Foreign-flagged airlines differ in their policies on ESAs. Volaris and LATAM will allow ESA pets on specific routes. Others such as British Airways do not recognize ESA status on any of their flights. Other foreign carriers may also follow the ESA pet policies, but they are not obligated to do so if their flight does not involve airports in the United States.

You will need to contact the airline and confirm that they will allow your pet on your route. Always remember, however, that there are countries that mandate that your pet arrive as air cargo, including ESAs.

More current information on airline policies on emotional support animals.

Note: Passengers intending to travel to the United Kingdom with service dogs need to arrange pre-approval clearance and pay a processing fee. You will need to contact the appropriate Animal Reception Center. We would note that your assistance animal must be certified by either the International Guide Dog Federation (IGDF) or Assistance Dogs International (ADI). Emotional support dogs that are not recognised as assistance dogs by the above organisations will not be permitted to enter the UK in the cabin of any airline.

Documentation

Some airlines may require that owners of service animals present evidence of certification of training if the animal displays unacceptable behavior. The airlines will look for physical indicators on the service animal including harnesses, vests, capes or backpacks. The markings on these items should identify the animal as a service animal. They are expected to sit at their owner's feet during the flight.

The airines are only permitted to ask those traveling with service dogs two questions:
(1) Is the dog a service animal required because of a disability and
(2) what work or task has the dog been trained to perform.

Additionally, several major US-based airlines are requiring behavioral, sanitation, veterinary health and liability forms to be completed and submitted at their websites.

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