I wrote a post a few weeks ago about proposed new rules for flying with service and support animals. Lucky for me, most Thinking Dog readers are kind and thoughtful individuals.

Deni wasn’t so lucky. That could be because she had more than 2,000x as many readers as I generally do … in just the first 3 days (and no, that’s not a typo).

The comments on her article, and on the proposed rules at the DoT site, reveal much about our society. And why the concept of ESAs has been so badly abused. They follow several general themes:

• People who hate animals, kids, anyone who writes about animals, and pretty much the whole world. (These are best ignored.)
• People who think all animals should be banned from airplanes, including guide and service dogs, due to their own (or others’) allergies. (Not gonna happen.)
• People who say they cannot or will not fly if they cannot bring their ESA.
• People who use service animals and oppose any sort of behavior or health check or documentation.

What is missing from this conversation, as well as from the laws and proposed new rules, is attention to the animals’ welfare and needs.

Some of the people who can’t or won’t fly without an ESA could well be able to meet the legal threshold for a service dog. Others have generalized and severe anxiety or anxiety specifically about flying, so the presence of an animal is of comfort and helps them cope.

I am sincerely empathetic. At the same time, I think that’s a lot of responsibility to place on an animal, especially one that has not been trained to work under stressful circumstances. Public access is stressful for any animal, but especially one that essentially lives in a familiar home, rarely leaving except, in the case of some dogs and cats, for walks around the neighborhood. Airports and airplanes are about as stressful a situation as I can imagine.

I also worry that someone with severe anxiety would be stretched to the limit taking care of their own needs and would be unable to safely handle an animal, intuit and meet its needs, and keep themselves, the animal, and other passengers safe.

The untrained pets used as ESA are often terrified by the commotion, cramped quarters, noise, smells, and general awfulness of airports and airplanes. And that is exactly the problem: No one is evaluating the animals or training them to get used to public access. People with ESAs do not have the right to take them in public (the ADA gives that privilege only to people with both a disability and a trained service animal) and no training is required, so even if the people wanted to prepare their animals, they cannot legally do so.

Like other pets, most ESAs spend the majority of their time at home. Then, suddenly, they are taken to the most stressful place possible, by a person who is extremely anxious. As a living being with needs and fears, the ESA needs and deserves the protection of its person — a person who at that time is very unlikely to be able to provide that protection.

The law currently allows anyone whose mental-health professional (or internet store) supplies them with a letter attesting to their own need for the animal. Nothing addresses the suitability of the animal or its welfare, and nothing safeguards the public from terrified animals (mostly dogs) behaving like terrified animals: Growling, yowling, snarling, lunging, biting, peeing, etc. It’s a testament to how resilient and generally amazing dogs are that there have not been far more bites.

I am a former service dog trainer and am adamantly opposed to creating barriers to access for people with disabilities. At the same time, I do not think it is possible to protect public safety — including the safety of service dog teams — without limitations, such as a public access test and health requirements.

Public access with a service dog in a no-pets area is a privilege that does not include the right to endanger others or trample their rights. The ADA builds that in; a service animal that is dangerous or behaving inappropriately can legally be excluded even if the person has a disability and the animal is fully trained to mitigate that disability. The current ACAA rules on ESAs do not. And it is not reasonable or realistic to expect TSA officers or airline gate agents to be able to assess which animals are safe and which are not — and to be effective at barring those passengers and their animals.

There are ways to make health checks and public access tests easy, certainly no more complicated than getting a disabled parking placard in most states.

Thousands of dog trainers are capable of administering a CGC test, for example. A public access test could be similar, and it could be conducted by any certified dog trainer in a place the team goes anyhow, like Walmart or the supermarket.

Keeping your dog healthy and being able to show that the dog is vaccinated are minimal standards when taking your dog anywhere, even the dog park.

I don’t see these as huge obstacles or burdens. One comment I saw talked about the nearest Walmart being over an hour’s drive and said having to go to a testing site would be an enormous burden. If that person never, ever goes to that distant Walmart, or anywhere else in public with their service dog, they wouldn’t need to do the test. If they do go there, even rarely, doing a test there once every year or so is not a huge ask.

Airlines could help out by keeping paperwork on file, though, as they keep seating preferences and contact details for mileage club members. Asking people to jump through the same hoops every time they fly is absurd, especially for anyone who flies multiple times a year. Linking the health certificate and other info on the team to a flyer’s frequent flyer profile, with a flag for annual updates, is very easy in our digital age.

Allowing only trained, professionally evaluated animals to fly in the cabins of airplanes, and asking that other animals either remain in carriers that fit under a seat or that their owners make other arrangements is common sense. It respects the rights and safety of people with disabilities who have trained their (mostly) dogs and rely on those dogs’ assistance. It also respects the rights and safety of everyone else.

My comments are, of course, my opinions; reasonable people may well disagree. I think that Deni wrote a solidly researched article that presents a real problem and suggests viable solutions. I encourage you to read it, read the proposed rules, and comment. The 60-day comment period opened Feb. 5 and ends in early April.