At the end of 2020, the U.S. Department of Transportation (DOT) announced that it revised its Air Carrier Access Act regulation on the transportation of service animals by air. We are working to update the information provided below to align with the changes. While we take the time to update our information, check out a summary of the changes available on DOT’s website. You can also find some additional information in DOT’s Aviation Consumer Protection’s article about service animals.
What disability law applies to airlines?
While the Americans with Disabilities Act covers airports and terminals, the Air Carrier Access Act (ACAA) covers the airline, the services they provide, and the airplane itself. All U.S. air carriers’ operations and airplanes are covered by the ACAA. All foreign air carriers’ flights that begin or end at U.S. airports and the aircraft being used on these flights are covered by the ACAA.
What does the ACAA say about service animals?
The ACAA defines service animals differently than the ADA does. The ACAA defines a service animal as any animal that is individually trained to provide assistance to an individual with a disability or any animal that assists an individual with a disability by providing emotional support. This means that the ACAA does not limit service animals to dogs.
Check out these TSA resources
The TSA has produced several helpful resources, including articles, brochures, and a video. They provide a lot of information, including the definition of a service animal, the rights of an individual with a disability, and tips for the traveler.
Service Animals (Including Emotional Support Animals) is an online article about service animals and things to know before traveling with a service animal.
Traveling with Service Animals is a YouTube video produced by the TSA. (It includes both audio description and closed caption text.) It is a helpful video for individuals with disabilities who are traveling with a service animal to, from, or within the United States.
Air Travel with Service Animals: Here are some important things to know before you go... is a pdf document that answers some basic service animal questions. It is also available as a tri-fold brochure.
How are airlines required to accommodate service animals?
Airlines are required to allow service animals and emotional support animals traveling with individuals with a disability to sit with them in the cabin of the airplane. If requested prior to the flight’s departure, the traveler must be given a bulkhead seat. In the terminal, airlines must provide animal relief areas. Upon request, airlines must escort individuals traveling with service animals to these areas. On the airplane, the traveler must provide for the animal’s food, care, and supervision.
How do airlines determine if a service animal is really a service animal and not just a pet?
Airline personnel may ask questions and request documentation in certain circumstances. The questions that may be asked, and the level of documentation that may be required, will vary depending on the individual’s disability and the type of service animal.
An airline is required to permit the service animal to accompany the individual with a disability on the plane if an individual has an obvious disability and:
- The service animal is wearing a harness, tags, vests, or backpack; or
- The person provides identification cards or other written documentation; or
- The person provides credible verbal assurances that the animal is a service animal.
If airline personnel are not certain of the animal’s status, even after being told that an animal is a service animal, additional questions may be asked, including:
- What tasks or functions does your animal perform for you?
- What has the animal been trained to do for you?
- Would you describe how the animal performs this task or function for you?
For emotional support or psychiatric service animals (even if they are dogs), airlines may require very specific supporting documentation 48 hours in advance of a flight.
So, I can bring my emotional support animal?
Probably, unless your emotional support animal is an unusual animal like a snake, reptile, ferret, rodent, sugar glider, or spider. Airlines may also exclude animals that are too large or heavy to be accommodated in the cabin, pose a direct threat to the health or safety of others, or could potentially cause a significant disruption of cabin service. In addition, the ACAA requires foreign airlines to transport only dogs as service animals.
What types of documentation do I need to provide for my emotional support animal or psychiatric service animal?
Airlines can request specific documentation and/or 48-hours advance notice for emotional support animals and psychiatric service animals. The documentation must: 1) not be more than one year old; 2) must state that the person has a mental or emotional disability recognized in the Diagnostic and Statistical Manual of Mental Disorders; and 3) state that the animal is needed as an accommodation for air travel or for activity at the traveler’s destination. The documentation should also state that the mental health professional is treating the individual; include the date and type of the mental health professional’s license; and include the state or jurisdiction in which the license was issued.
The documentation does not need to include the traveler’s diagnosis.
Traveling to Hawaii?
The Animal Industry Division has issued a Guide & Service Dog memo. It defines service animals under state law and describes the process for bringing a service animal into the state.
What other ADA National Network resources do you have about flying with a service animal or emotional support animal?
The Great Lakes ADA Center has developed a webinar called “Home, Community or Travel: Rules for Service Animals are not the same.” It’s an hour and a half long webinar that answers questions about common disability laws, including the ACAA, and the protections they provide for individuals with disabilities and their service animals.
“Air Travel for Individuals with Disabilities: Intersection of the Air Carriers Access Act and the ADA” is a webinar developed by the Northeast ADA Center. This hour-long webinar provides an overview of the ACAA and the ADA on air travel – from booking a flight to boarding and deplaning. Issues such as emergency evacuation and traveling with a service animal are addressed.
The Northeast ADA Center has also created a helpful infographic, “Service Animals on Airplanes”, available on their Facebook page.