HUD Also Tightening Rules for Emotional Support Animals

sign reads "no pets allowed. service dogs welcome."

The DoT is not the only government agency that is tightening its rules around service and emotional support animals. On January 28, HUD, the Department of Housing and Urban Development, released a notice of its updated rules.

A quick review:

  • The ADA, the Americans with Disabilities Act, allows people who use service dogs to take their service dogs with them to most public places.
  • Air travel is not covered by the ADA. The Air Carrier Access Act (ACAA) covers air travel. The Department of Transportation (DoT) announced proposed changes to the rules around travel with service and emotional support animals. Public comments will be accepted until mid-March.
  • HUD governs housing laws. The new rules have been announced without a public comment period.
  • The ADA public access laws apply only to service dogs (and some miniature horses); a person who has gotten an accommodation for an assistance animal that is not a service dog does not have the right to take that animal to public places that are not open to pets (for example, restaurants, stores, etc.).

HUD’s goal is to help housing providers understand their rights and obligations — and to help housing providers determine whether a request for an accommodation is legitimate.

Both the HUD and the DoT are reacting to dramatic increases in the number of requests for accommodation of emotional support dogs, including requests to allow a huge variety of animals, not always animals that are commonly owned as pets. They are also getting large numbers of requests with no or minimal documentation, including letters provided by online providers.

HUD’s new rules:

  • Adopt the ADA definition of a service dog
  • Treat service dogs and other assistance animals differently
  • Require that individuals ask for an accommodation for an assistance animal
  • Require that individuals provide “information that reasonably supports that the person seeking the accommodation has a disability” — and make the truth and accuracy of this information a requirement of the lease (that is, if the person is later found to have lied about having a disability, the housing provider could evict them)
  • Require that individuals provide “information which reasonably supports that the animal does work, performs tasks, provides assistance, and/or provides therapeutic emotional support with respect to the individual’s disability” with a similar provision about the accuracy of the information

Finally, with rare exceptions, housing providers do not have to accommodate animals that are not commonly kept in households as pets.

The document includes guidelines on what constitutes a “reasonable” accommodation and on how to document a need for an assistance animal that is not a service dog.



Cali Is Excited about Meeting Her New Best Friends

Cali is sure you’re going to be her new best friend!

Cali and I are working on becoming a visiting “therapy” dog team.

We met with the coordinator of the Wind River Canine Partners Therapy Dog Program this week for our first evaluation. We spent about an hour walking around in a Cabela’s store (very dog-friendly). Cali was excited about going shopping! And meeting new best friends!

I had warned the trainer that Cali’s main weakness is getting overly excited about meeting someone. Anyone. Especially men. She saw exactly what I meant when Cali pulled, hard, toward her. A random stranger in a parking lot? Clearly Cali’s long-awaited best friend. Oh wait, that clerk just inside the door: Definitely a best friend. Oh, there’s another one … and a shopper. Oh! A family with a kid!! A dog in a shopping cart!

After greeting a few people, Cali got down to shopping. It’s hunting season in Montana, so … lots of weird lure-type things with feathers? The plastic packaging wrap did not throw Cali off the scent, and she found them fascinating. She was not at all interested int he fake and dyed feathers, only the natural ones. She loved the fishing lures too. Mild curiosity about the actual equipment. No interest in plastic antlers.

Then … the toy department. The hobby horses who made neighing and galloping sounds were mildly interesting. But the small rocking horse, pink, with sparkly green eyes: Downright terrifying. It had a face. It moved unpredictably. And it was looking at her. She was not going near that thing no way no how … well, maybe just a quick sniff. Oh, wait, someone dropped a cookie nearby; maybe she can just reach over and … it’s looking at her again!

That was scary.

More people to greet, more toys to sniff. What’s this? A fake man with no head? Humans have the weirdest toys … Uh oh, that horse again. Huh, maybe it’s okay with cookies …

It was a tiring trip. Cali slept all the way home.

Cali passed with flying colors. Perfect temperament, obviously loves meeting people.

The handler? She needs some work.

Once we’ve improved our handling skills, we can start visiting. Cali would like to try visiting people at the hospital or maybe the veterans center. Anyplace without rocking horses is fine.

Dog Therapy

Cali, a golden retriever, sits surrounded by flowers

Cali’s a natural. She intuitively knows when people need a hug. She gives the best hugs, too.

Just this past week, she comforted a stressed-out friend, soberly inspected a neighbor’s injured leg and offered reassurance, and snuggled with another anxious friend.

That’s why I am hoping to get her registered as a Pet Partner. She loves meeting people and is so sweet with people who need the comfort of a dog to pet or hold. So, on Saturday, I volunteered to help out at the evaluations of three dogs who were becoming Pet Partners. I wanted to see what the test looks like (it has been several years since I last did one) and where we might need work. All three dogs, a miniature poodle, a medium-sized mix, and a young golden retriever, did very well.

I’m not sure we’ll pass, though. Cali knows what to do. She’s been through obedience classes and is generally a well-mannered dog. Until her newfound fascination with squirrels, I didn’t think she had an aggressive or predatory bone in her body.


When Cali gets excited, she loses her mind. She gets excited when she knows she might get a treat from someone. I could make sure that no one ever gave her a treat on our Pet Partner visits, though that would be hard. Sometimes, though, she gets excited just because she thinks she gets to meet someone new. Since that is the whole point of Pet Partner visits, I am not sure what to do.

Just yesterday, we were heading out for a walk, and a neighbor, someone I hadn’t met, was approaching. Cali went nuts. Pulling, hard, wagging her whole body… it was all positive energy, but not at all appropriate for visits. Even if I carefully avoided visits where anyone might be frail or easily knocked over. And if she got this excited at the test, there’s no way we’d pass.

I’m going to sign us up for some classes where she’ll get some practice listening to me with a lot of distractions and paying attention even when interesting people and dogs are all around us. I’m working really hard on not letting her get treats or petting when she’s pulling. But the world doesn’t always cooperate. Like the time she pretty much had treats thrown at her, strewn in our path, as we walked through Ace to the dog-food aisle (last week). Or the people who assure me that “it’s all right” that she’s pulling as they lean down and pet her and oooh and ahhh over her — ignoring my pleas to wait until she sits. It is not all right!

It seems unfair that the only way to try to get her what she wants — chances to meet more people — is to deny her the chance to meet people. And that’s not even guaranteed to work. I’ll let you know how it goes. The next evaluations are in November. Cali will be 5(!!) in December. If that sweet 15-month-old golden could pass (he did, with flying colors) she should be able to pull it off!