The US Department of Transportation has just issued a final ruling that will greatly change how emotional support animals (ESAs) can travel on flights. This is major, and has the potential to end the concept as we know it.
What are emotional support animals?
An emotional support animal is any animal companion that offers some type of benefit to an individual with some form of disability. This is different than a service animal, which is specially trained and might assist someone who is blind or deaf, for example.
The ESA concept is only a thing in the US, and it has been controversial, as we’ve seen people bring ESAs that range from turkeys to pigs to miniature horses onto planes. The reality is that getting an ESA certification has been quite easy, as there are doctors online who can provide it (just Google and you’ll see all the options).
The number of ESAs traveling on planes has skyrocketed in recent years for a couple of reasons:
- Airlines haven’t been able to charge for ESAs, so it’s a way to take a small pet in the cabin without having to pay a fee
- On most airlines, only pets up to 20 pounds are allowed in the cabin, and many people haven’t wanted to put their pets in the cargo hold (for good reason); having an ESA is a way to get around that, since you can bring a larger animal into the cabin
DOT cracks down on emotional support animals
The US DOT has issued a final ruling on emotional support animals, which gives airlines the discretion to end the ESA concept as we know it, should they so choose.
Here are the key changes from this ruling:
Emotional support animals are no longer service animals
The DOT is no longer categorizing emotional support animals as service animals. Service animals are being redefined, and have new restrictions:
- Airlines may limit service animals to dogs, may limit each traveler to two service animals, and may require service animals to fit on their handler’s lap or within their handler’s foot space on the aircraft
- Service animals have to be “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”
- Airlines can require passengers to remit a completed hardcopy or electronic version of the DOT’s “Service Animal Air Transportation Form” as a condition of transport
Again, these new restrictions apply to service animals, and emotional support animals are no longer categorized as such.
Airlines can start charging for emotional support animals, and restrict them
The biggest implication of this policy change is that emotional support animals are now going to be categorized as pets, rather than service animals. What does this mean?
- Airlines will be able to charge travelers for their ESAs, rather than having to allow them on for free
- Not just that, but airlines can apply their weight and size limits to ESAs going forward; for example, most US airlines only allow in-cabin pets weighing up to 20 pounds, so airlines could apply those restrictions
As the ruling explains:
“Treating ESAs as service animals amounts to a price restriction that sets the price of accommodating passengers who travel with ESAs at zero dollars, despite the fact that airlines face non-zero resource costs to accommodate those passengers.”
The DOT claims that this could lead to $54-60 million in increased fees for airlines. I’m not sure that would actually be the case, assuming airlines have the same restrictions on ESAs as they have on pets. Many ESAs are above the current weight and size limits for pets, and therefore people potentially won’t even pay to allow these animals on planes.
This is an opportunity for airlines to innovate
I absolutely think the emotional support animal concept has been abused, and people bring all kinds of poorly behaved pets on planes, and take up other peoples’ space. But I also think the reason this has been abused so much is because of the lack of options airlines have provided for traveling with pets.
The way I view it, this is a great revenue opportunity for airlines, and also an opportunity for airlines to differentiate themselves (just as we see some hotel groups that are totally dog friendly, while others aren’t).
Everyone knows their own pet best, but in my opinion it’s cruel and even somewhat dangerous to put many pets in a cargo hold. Now, in fairness there’s a difference between someone who wants to take their miniature horse with them on every vacation for free, and someone who is moving across the world and just wants their pet to be as safe and comfortable as possible.
I understand this is a slippery slope, but if someone has a 25 pound senior dog and is moving across the world, I personally find it a bit heartless to say “too bad, just put ’em in the cargo hold.” In fairness, I love dogs, though…
The way I view it, there are a couple of directions airlines could go without completely restricting in-cabin pets to 20 pounds:
- Airlines could continue to allow ESAs but charge the standard pet fees for them, which would likely greatly reduce the number of people traveling with them, and would be a revenue opportunity for airlines
- Airlines could actually get innovative with in-cabin pet travel; how about allowing one or two pets per flight, under the condition that a full row of seats (or something) is purchased for the person traveling with the animal
Now I’m sure some people will say “well I’m allergic to dogs, get over your pet.” Fair enough, and I get that’s not easy, but at the same time dogs are already allowed on planes as pets.
Presumably people are also allergic to dogs under 20 pounds, and those are currently allowed in the cabin. There shouldn’t be a difference there, as I’m all for keeping a cap on how many pets can travel in a cabin (which already exists).
The Department of Transportation has cracked down on emotional support animals. Airlines no longer have to categorize emotional support animals as service animals, but rather can categorize them as pets.
This means that airlines can start charging for these types of animals, and can also apply the weight restrictions on in-cabin pets (which is typically 20 pounds) to these animals.
While I’m not opposed to the spirit of this change, I do hope some airlines use this opportunity to innovate how we can travel with our pets. For animals over 20 pounds, there should be an option other than the cargo hold, in my opinion. This could be a good revenue opportunity for airlines, and also a point of differentiation.