“Final Word” on Flying Service Animals

Your seat-mate on your next flight?

The US Transportation Department (DoT) has issued a “final” statement on service animals in air transportation. I’m a bit skeptical of that finality, but it’s definitely worth taking a look at what is the current last word.

When I last looked at this, airlines were issuing strict new policies, and the DoT was taking public comment on changes it was considering. They received more than 4,500 comments, and have released their final (for now) policy.

Here’s a summary:

  1. Airlines cannot categorically ban specific breeds of dogs. They also cannot categorically refuse to transport all animals that are not dogs, cats, or miniature horses. They can refuse reptiles, ferrets, rodents, and spiders. The “emotional support peacock,” and possibly the pig, however, appear to be cleared for takeoff.
  2. Passengers may travel with a total of three service animals, including one ESA; the DoT will focus enforcement on passengers who’ve been prevented from traveling with up to 3 animals, but will not allow airlines to enforce a strict limit at all.
  3. Airlines may not categorically ban animals over a specific weight, but they are allowed, on a case-by-case basis to refuse to allow an animal in the cabin if it is too large or heavy. That could mean weight- or size-related bans on certain smaller aircraft, but not, as some airlines have tried, across-the-board weight-based bans.
  4. Airlines may ban “service” animals that are younger than 4 months, since  “those animals would not be trained to behave properly in a public setting.” But the DoT does “not anticipate exercising our enforcement resources” in this area.
  5. Airlines may not ban emotional support animals (ESAs) on flights longer than 8 hours. They can however require anyone traveling on longer flights with a service animal to provide documentation that the animal either “will not need to relieve itself on the flight or can do so in a way that does not create a health or sanitation issue on the flight.” There’s no hint as to how someone might document that. They may also require 48 hours’ notice that a passenger has a service animal and they may also require early check-in, in person, in addition to the documentation.
    Note that the document uses “service animal” as a broad term that includes ADA service animals, emotional support animals (ESAs), and psychiatric service animals (PSAs). I believe that this will prove to be an enormous hassle for people traveling with, say, guide dogs or mobility service dogs, on long flights.
  6. Airlines may request documentation from a medical professional from passengers seeking to travel with an ESA or PSA and can request but cannot require that passengers use a specific, airline-created form.
    In addition, they may ask any passenger traveling with a service animal “limited questions” to determine the passenger’s need for the animal, regardless of whether the animal has a tag, vest, or other service dog paraphernalia. What these questions are is not stated.
    Note that the ADA does not apply to air travel, so airline personnel are not limited to the ADA questions (whether it is a service animal and what task it does).
  7. Airlines may not require people with disabilities using task-trained, non-ESA/PSA service animals to produce documentation in advance of travel. However, airlines may request documentation related to “vaccination, training, or behavior” if the airline reasonably believes the documentation would help assess whether the animal poses a “direct threat to the health or safety of others.”
    There is no explanation of what form this documentation might take or how it might help make such a determination, so this point could be very problematic. They do not envision taking enforcement action against airlines asking for this documentation.
  8. Airlines may require passengers traveling with ESAs or PSAs to check in, in person, in the airport lobby and present their documentation — prior to entering the “sterile” area (post-security check). They may also require these passengers to provide 48 hours’ notice that they are traveling with an ESA or PSA and require them to check in up to an hour earlier than other passengers. These requirements do not apply to non ESA/PSA service animals (which are not defined).
  9. Airlines may require that service animals of all types be “contained” (including leashed), and complaints will be evaluated case-by-case. In general, requiring some means of tethering is allowed.
    But … While airlines may make other requirements to ensure safety and to ensure that other passengers have use of their “foot space” — but they also have to  allow the animal to provide emotional support or perform tasks. Translated, that means people may be permitted to remove their ESAs from crates (and we all know that people do so even when it’s not permitted).
  10. Airlines cannot limit the total number of service animals on any flight (including ESAs and PSAs).

That’s a lot. It’s similar to the interim document that has been in force for a little over a year. But it certainly does not address the clear problems that triggered the new document, which included rampant fakes, non-domesticated animals with no training traveling in crowded planes, along with untrained, stressed, and sometimes aggressive dogs, and people with trained service dogs being hassled and worse.

Under the new policy, the documentation that airlines can require for non-ADA service animals is vaguely defined, and what they can ask of service dog users is not defined at all. Airlines still will rely on check-in personnel, who are not animal behavior experts, to evaluate whether an animal poses a risk. They’ll still face pressure to accommodate unsuitable animals. Lots of them. I’m imagining planes full of people with 3 “service” animals apiece, all outside their carriers.

Walking into the lobby of an airport is an unusual activity and would be stressful for an animal not trained for or used to public spaces. Since there are no laws that grant public access to people with ESAs, and no training is required, this describes most ESA.

But that’s just the beginning; an untrained staffer might not notice that an animal is stressed at this early stage. Airline personnel have no expertise or way of evaluating whether an animal will remain calm under stress or whether the person can safely handle the animal during travel. Many handlers wouldn’t notice or be aware of signs of stress. The animal’s stress level is likely to rise as new, weird experiences pile up: TSA check; maybe riding on a tram of some sort; sitting in a crowded gate with loud noises and anxious people; being stuffed under a tiny seat, hemmed in by strangers; more loud noises and weird smells … Under increasing stress, it’s likely that more animals will react quite naturally — and people will get hurt. And when the untrained, stressed-out dog stuffed under the middle seat bites the passenger in the window seat, that poor person is still trapped in a tiny space with no way out.

The DoT’s mission was to protect the safety of all travelers, the rights of people who are legitimate service animal users, and the safety of traveling service and support animals. The new regulations were intended to address a tsunami of fake service and emotional support animals on airplanes, traveling with people ill-prepared to handle them safely. I don’t think that this document comes close to accomplishing any of those goals. In fact, the new policies might invite even more abuse than the old rules.

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How do you choose a boarding facility?

A white golden retriever, Jana, reclines on a sofa
Leave your dog in the lap of luxury when you travel

You’re going on a trip. Hooray!
Your dog isn’t. Now what?

First, consider your options.

You could have a sitter stay at your house. Advantages include less disruption of the dog’s routine — this was my go-to when Jana was elderly and anxious — and it’s convenient. No drop-off or pick-up. But you do need to prepare the house, maybe make up a guest bed, and be prepared for a relative stranger to live in your space. You have to really trust the person.

You could leave the dog at a sitter’s home. This is easy, and often less expensive than a boarding kennel. The dog is likely to get lots of attention (if you’ve chosen your sitter well). You also need to really trust the person.

Some sitters take only one or two dogs at a time, while others board multiple families’ dogs. Find out how many other dogs will be there, and decide whether that will work for your dog. Clarify what exercise and play opportunities the dog will have. Ask about sleeping arrangements, and ask how much time the dog(s) are left home without human supervision.

If these options don’t work for you, you might look at boarding kennels. These range from a few cages at the back of a vet hospital to luxurious pet ranches. The price and the amenities do not always correlate, so visit any place you are considering and ask a lot of questions. Basic, essential questions include:

  • How many dogs are boarded at a time, and how many staffers are on each shift?
  • Is someone on site overnight? If not, what time do they leave? What time do they come in? Does someone come in in the late evening to let the dogs out? Or do the dogs have access to a potty area? Your goal is to find out how many hours the dogs are in their kennels or crates. In some places, it’s 12+ hours!
  • Where do the dogs sleep?
  • What exercise and play opportunities are included? What costs extra?
  • How many hours a day is the dog kenneled / crated?
  • Where do the dogs sleep? Do they have blankets / beds or are they in bare runs?
  • Are they fed their own food or does the kennel feed everyone an in-house food (should be dog’s own diet)?
  • What vet do they call if there’s a problem (should be your own vet)?
  • How are dogs grouped for play? How are they supervised?
  • How do they handle special diets / medication and avoid mistakes?
  • Do they send you updates or photos?

Look at the kennels and play areas. Do they look secure? Kennels should have solid walls and, ideally, be separated. Long rows of mesh fences are a bad sign. Being kenneled right next to other dogs, with no way to “den” or get away from the other dogs’ gaze is very stressful for most dogs.

A kennel I used a long time ago had several small garden sheds set up for the dogs’ sleeping accommodations. Each had its own dog door to its own potty yard, available all night. The dogs were “tucked in” at night by a staffer, who stayed on site overnight. That’s a great setup.

Another kennel I used had regular wire-fenced kennels (not for my dog!) and a few separate rooms. With actual walls. Our dogs could share a room (with no non-family dogs), and have their own bedding. They were away from the chaos and stress of the kennel area. It was still stressful and not ideal, but it was an acceptable solution.

Finding the right place requires doing your homework. You might visit several kennels or interview a half-dozen sitters before choosing. Get recommendations from picky friends if you can. Once you’ve been to a kennel or sitter, pay close attention to your dog’s reaction. Is she dragging you out of there or happily interacting with the staffers while you settle your bill?

Oh, and have a great trip!