DOT Updates Service Animal Guidance: What Advisors Need to Know

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The U.S. Department of Transportation (DOT) has released its final statement on its enforcement priorities regarding service animals on flights, following a couple of years in which airlines have updated their policies on emotional support and service animals following a series of high-profile, in-flight incidents. The statement provides guidance about the DOT’s interpretation and enforcement of the existing service animal rules. 

Parts of the new statement apply to service animals, while others apply to emotional support animals. The distinction between the two types is important, because during the period when major airlines were updating their rules regarding support and service animals, many disability advocacy organizations argued that the earliest versions of the new rules were too burdensome on customers with service animals. The organizations said that, because service animals are specially trained, they are safer than emotional support animals. 

While the full statement is available on the Department of Transportation’s website, here are a few key takeaways for travel advisors:

  • Airlines can ask for service animal documentation. The DOT says that required documentation can relate to the service animal’s vaccination, training or behavior so long as it can reasonably help the airline in determining if that animal is a safety threat. That means airlines can ask advisors and their clients to provide this documentation before traveling. 
  • Airlines can require advance notice for support animals, but not service animals. Advance notice for service animals was a key point of contention during the first round of updates to airlines’ animal policies. The DOT has ruled that airlines cannot require advisors and their clients to provide such notice for travel with service animals, but they can for travel with emotional support animals. 
  • Airlines can require lobby check-in for support animals. This means that advisors and their clients can be asked to use lobby check-in when traveling with emotional support animals; airlines can also require checking in one hour before the check-in time of the general public. 
  • More on species limitations. Many of the incidents surrounding the airlines’ policy updates included passengers traveling with unusual animals and garnering media attention, such as one incident in which a woman attempted to travel with an emotional support peacock on a flight out of Newark. In its latest guidance thee DOT said that, while regulations have a broad definition of service animals, it will prioritize ensuring that the most commonly recognized animals are accepted: dogs, cats and miniature horses. “Nevertheless, airlines are still subject to enforcement action if they categorically refuse to transport other species that they are required to transport under the current rule,” the DOT said. Airlines cannot, however, restrict certain breeds, including specific dog breeds, from flying, although they can find that any specific animal, regardless of breed, poses a “direct threat.”

The support and service animal policies for the “big three” airlines, all of whom have issued updates over the past few years, are available below:

The full DOT statement is available here

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