Service Animals vs. ESAs: New Air Travel Rules for 2021

When it comes to air travel regulations, both emotional support animals and service animals have gotten a bit of a pass so far. Current regulations allow them to ride along with their owner at no additional cost, and with very little restriction – the main requirement was that the owner shows proof that the animal is actually a service animal or ESA. That might sound like a triumph for disability advocates, but it’s turned out to be a mixed blessing for other travelers. 

According to the National Service Animal Registry, one problem is related to the training of each ESA. Because any given emotional support animal may or may not be well-trained, simply having the designation of an ESA isn’t a guarantee that the animal – no matter how sweet – will behave itself on a plane. This has resulted in a large volume of complaints from airline passengers who had to deal with animals that weren’t toilet-trained or adequately restrained. These animals are allowed certain freedoms because of their status as ESAs, but they don’t necessarily have the discipline to avoid causing problems.

Service Animals

Not only were ESAs the source of complaints, but some pet owners found out about the perks they could get if they could convince airline staff that their pet was, in fact, an emotional support animal. Because the requirements for an animal to become an ESA are so basic, it’s hard to disprove this kind of claim. There’s no special training needed, and as long as the animal isn’t overtly aggressive, who’s to say that the owner isn’t telling the truth? Between real and fraudulent ESAs, there have been numerous animal-related issues on airplanes in the last several years.

Because of this, the DOT will be introducing new regulations in the first months of 2021 that changes the status of ESAs on planes. More than a few people feel strongly about the need for such changes; when the DOT announced the upcoming rule changes in February of 2020, more than 15,000 people commented with their opinions and reactions. Some of the changes have actually been influenced by these same comments; if the rules are going to be changed, it’s important that they serve the needs of the people who will be affected by them. Even though it means stricter rules for owners of ESAs to follow, it could hopefully lead to clearer definitions of ESAs one day, letting them enjoy the same status as service animals again. 

Once the regulations are in effect, an emotional support animal will have to comply with the same rules as ordinary pets. They can still be brought into the plane’s cabin as long as they meet the size and weight requirements, but they’ll have to be in a cage or on a leash, depending on what the airline’s policy is. They’ll also be subject to the same fees as other animals. 

What happens with the service animals, though? There are changes coming up for them too. They’ll still be able to accompany their owners with no additional fees, but airlines may require the dog to fit on their owner’s lap or under an airplane seat, or to wear a harness. The requirements for documentation have also changed – now, owners of service animals will have to present two documents from the DOT at whichever airline they’ll be traveling with. One document states that the dog in question is a certified service animal, and that it’s trained to mitigate the effects of its owner’s disability; the other document states that the service animal is trained to relieve itself appropriately when in public. 

Even though a service animal’s specific training isn’t necessary for good behavior on an airplane, there’s a reason why airlines trust them with fewer restrictions than ESAs. They’re simply operating under the assumption that if a dog is able to gently disrupt a PTSD flashback or guide a deaf person through a crowd, it’s also been trained to sit quietly when it’s told, and to avoid relieving itself where it shouldn’t. These are really the two most important factors for a pet to master for air travel, and service dogs are even certified – airline staff don’t have to guess whether the animal is bona fide or not, like with ESAs. 

It’s true that service animals aren’t always dogs, but for right now, the upcoming regulations only include dogs. Airlines will have the right to exclude miniature horses, birds, cats, rabbits, and all other species of service animals from the plane. 

For individuals with ESAs who will be traveling by plane after the regulations have taken effect, it would be smart to call ahead and check with the airline about their pet size requirements. In some cases, the emotional support animal is needed for the owner to even board the plane; if the airline decided that the crate was too big and had to be moved to the cargo area, that could be a serious issue. Even if you can’t make the flight without being accompanied by your 70-pound Labrador, you can’t count on airline staff making an exception for you. Under normal circumstances, it’s likely that the majority of emotional support animals are tolerable to be around, or even really fun; but being in an airplane with a couple hundred other people isn’t exactly a normal circumstance. Probably plenty of the animal-related complaints were about animals that were usually well-behaved, but simply weren’t trained well enough. 

There are changes ahead for the owners of both service animals and ESAs, but fortunately, there are still ways to adapt. Interestingly, some of the same people who called for tighter exclusions with ESAs and air travel are also calling for the definition of an emotional support animal to be made more specific. With a change like that, we could eventually see ESAs being included with service animals as companions in air travel. For now, the regulations might seem unsatisfactory to some people, and that’s understandable; after all, who wants to be told that they’ll have to jump through twice as many hoops to take their support system along? However, it won’t be this way forever – and who knows what the future could hold. 


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