Air Travel
Service Animals
The ACAA prohibits discrimination by airlines based on disabilities. (This article discusses air travel only within the continental United States; different rules and regulations may apply when traveling to Hawaii, Puerto Rico, or internationally.) ACAA regulations require airlines to allow disabled passengers to travel with up to two service animals at no charge. Under the ACAA, a “service animal” is “a dog, regardless of breed or type, that is individually trained to do work or perform tasks for the benefit of a qualified individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability” (14 C.F.R. § 382.3).
Service animals in training are not considered service animals under the ACAA. This means that the four largest airlines (the “Big Four”) in the United States—American Airlines, Delta Air Lines, Southwest Airlines, and United Airlines—have different policies on how to accommodate them. American and Southwest classify service animals in training as pets. Delta does not recognize a service animal in training as a service animal but allows them to travel with a professional trainer en route to their owner. United allows service animals in training to fly with their trainers for free.
Emotional Support Animals
Although emotional support animals used to be recognized as service animals, this has changed in recent years. Now, emotional support animals are relegated to pet status and can only fly with a passenger at the airline’s discretion. That said, airlines are required to treat psychiatric service dogs the same as other service animals. Psychiatric service dogs are trained to perform specific tasks to detect oncoming psychiatric episodes and lessen their effects. For example, a psychiatric service dog may be trained to remind their owner to take their medicine, alert them of an oncoming panic attack and perform a specific action to help lessen or avoid the attack, interrupt self-mutilation, or remove them from dangerous situations.
Pets
Each of the Big Four allows small domestic cats and dogs to travel as pets. Delta also allows household birds. When flying with an emotional support animal or pet, you should carefully review pet the policies of the airline you are traveling with. Some airlines do not allow emotional support animals or pets in certain areas of the plane or on specific plane models. Furthermore, most airlines have a maximum number of animals (other than service dogs) allowed per flight or ticketing class. Consider verifying that your flight or ticketing class has not reached the maximum allowance.
Booking
When booking your flight online for any of the Big Four airlines except Southwest, you can indicate on the online form that you are traveling with a service animal or pet. If you are booking a flight on Southwest, you should contact the airline directly if you plan to bring any animal with you. It is important to consider location and legroom when picking your seat. Generally, airlines do not allow any animals—service dogs, emotional support animals, or pets—in exit rows. The Big Four require that your service dog fit in your foot space or under your seat. But if your service dog is smaller than a two-year-old child (the actual unit of measurement provided by American and United), it has the additional option of sitting on your lap. You can also keep your service dog in a carrier stowed under the seat in front of you, provided the carrier fits. Regardless of which option you choose, your service dog cannot encroach into an aisle or another passenger’s space.
If your service dog is too big to fit, the airline must offer you another seat within the same ticketing class where your service dog can be accommodated. Still, this is only if such a seat is available—airlines are not required to move other passengers to accommodate service animals. If no such seats are available, the airline must offer to transport your service dog in the cargo hold for free or move you to a later flight if space is available. American and Delta also allow you to buy the seat next to yours, if available, so that your service dog can use that seat’s foot space in addition to yours.
Requirements
Your service dog can be any breed or type. The Big Four require service dogs to be at least four months old. If traveling with an emotional support animal or pet, you should verify how old they must be to fly with your airline. Delta and United require emotional support animals and pets to be at least two months old to fly.
Each of the Big Four requires that your emotional support animal or pet remain in their carrier. Your animal’s carrier usually counts as your carry-on item. The average fees to carry on an emotional support animal or pet range from $125 to $150 per kennel each way. Your animal’s carrier must be well-ventilated, leak-proof, and fit under the seat in front of you. The carrier must be large enough that your animal can comfortably move around without touching or sticking out from the sides. The maximum carrier sizes vary with each airline. The Big Four maximum carrier measurements are as follows:
- American
- Mainline flights on American: 19” x 13” x 9”
- Regional flights on American Eagle: 16” x 12” x 8”
- Delta
- For most aircraft types: 18” x 11” x 11”
- Southwest
- Southwest Airlines pet carrier: 17” x 10” x 9.5”
- Other pet carriers: 18.5” x 13.5” x 9.5”
- United
- Hard-sided: 9” x 17.5” x 12”
- Soft-sided: 11” x18” x 11”
Inquiries and Documentation
Airlines can only ask two specific questions about your service dog: (1) is your animal required because of a disability, and (2) what work or task has your animal been trained to perform? The ACAA prohibits airlines from asking other questions about your service animal or disability.
On top of these two questions, airlines may require you to complete and submit two documents before allowing your service animal to fly. First, airlines can require a U.S. Department of Transportation Service Animal Transportation Form. This requires you to attest to your service dog’s health, behavior, and training. It also asks for your service dog’s weight, breed, vaccination information, and vet information. Second, for flights lasting eight hours or more, airlines can require a U.S. Department of Transportation Service Animal Relief Attestation Form. This form asks you to confirm that your service dog “will not need to relieve itself on the flight, or that the animal can relieve itself in a way that does not create a health or sanitation issue on the flight” (14 C.F.R. § 382.75).
These forms can be found on the Department of Transportation’s website, the airline’s website, or at the airport. Alternatively, airlines are required to mail the forms to you on request. You must complete these forms on or after your ticket purchase date. Airlines may require you to provide these forms in advance of your flight. Generally, airlines with this requirement ask that they be submitted at least 48 hours before your flight. But if you arrive at the airport on the day of your flight and realize that, in the chaos of preparing for your trip, you forgot to submit the forms, there is no need to panic. The airline must still make reasonable efforts to accommodate you and your service dog without delaying the flight. This does not mean you are guaranteed or entitled to travel on the flight you booked; it only requires airlines to make reasonable efforts to accommodate you. You should keep these forms, or copies of them, handy while in the airport and aboard the plane. If your trip includes a flight on a partner airline, you must contact them and provide the required forms for traveling with a service animal.
Checking In
You should arrive at the airport early if traveling with any animal to ensure that they meet the size restrictions and that all required forms have been completed and received. This is especially true for emotional support animals and pets due to the additional requirements and restrictions. Some airlines require you to check in with one of their agents before flying with a service animal. American will not give final approval for your service dog to fly until you arrive at the airport and one of their agents determines that your service dog will safely fit at your feet. Southwest requires you to check in with an agent at the ticket or departure gate counter to present the necessary forms.
At the Airport and in the Air
Emotional support animals and pets must stay in their carrier except when going through a TSA checkpoint. At that time, you will be asked to take your animal out, place its carrier on the conveyor belt to be x-rayed, and carry or walk it on a leash through a metal detector.
Service dogs are not required to be in a carrier, but they must be either harnessed, leashed, or tethered the entire time you are in the airport and on the plane. Your service dog must also behave appropriately. You might be prevented from bringing your service dog with you if they display disruptive or aggressive behavior that you cannot successfully correct or control, including but not limited to:
- growling;
- biting or attempting to bite;
- jumping on or lunging at people;
- relieving itself in any area not designated as an approved animal relief area (offered by every airline in the United States);
- barking excessively (except when in response to a handler’s needs); and
- eating off seatback tray tables.
If your service dog exhibits any of these behaviors, the airline may prevent you from bringing them into the plane’s cabin or reclassify them as a pet. The airline’s standard pet policies and fees will apply if your service dog is relegated to pet status.
If you believe an airline violated your rights under the ACAA, you can ask to speak with a complaints resolution official (CRO). A CRO is the airline’s expert on disability accommodation issues. Airlines are required to make one available to you, at no cost, in person at the airport or by telephone. If you are unsatisfied with the airline’s response, you can make a complaint on the U.S. Department of Transportation’s website.
Hotels
The ADA covers public accommodations, including hotels and inns. Under the ADA, hotels are required to accept service dogs of any breed at no charge. The ADA defines service animals as any guide dog, signal dog, or other animal individually trained to work or perform tasks for people with disabilities. The work or task your service animal has been trained to perform must be directly related to your disability. You can train your service dog to perform these tasks yourself and do not have to use a professional service dog training program. But, while your service dog is in training, they are not considered a service animal under the ADA.
Animals whose sole job is to provide comfort and support—such as pets and emotional support animals—are not service animals under the ADA. That said, the ADA distinguishes between psychiatric service animals (see above) and emotional support animals. Psychiatric service animals are entitled to the same accommodations as any other service animal. On the other hand, the ADA does not require hotels to accommodate pets or emotional support animals. At the same time, some state or local governments grant greater rights to emotional support animals than required by the ADA. Check with your state and local government agencies to learn about these laws.
Miniature Horses
While the ADA limits its definition of service animals to include only dogs, the Department of Justice’s ADA regulations have a separate provision allowing you to use a miniature horse as an alternative to service dogs, subject to certain limitations. The miniature horse must be individually trained to assist an individual with a disability. Miniature horses are excluded from the official definition to allow flexibility where using a service miniature horse would not be appropriate.
Hotels must make reasonable efforts to accommodate a disabled person with a service miniature horse. Factors the hotel should consider are:
- the type, size, and weight of the miniature horse and whether the facility can accommodate these features;
- whether the handler has sufficient control of the miniature horse;
- whether the miniature horse is housebroken; and
- whether the miniature horse’s presence in a specific facility compromises legitimate safety requirements necessary for safe operation.
Documentation and Inquiries
The ADA does not require that service animals be certified or licensed. In fact, the ADA prohibits hotels from requiring documentation, such as proof that a service animal has been certified, trained, or licensed as a service animal. So, do not fall for any of the many websites selling service animal certification or registration documents. They are not required to use your service animal, and the Department of Justice does not recognize them as proof that your dog is a service animal.
Hotels may only ask you the same questions as airlines: (1) is your animal required because of a disability and (2) what work or task has your animal been trained to perform? They cannot ask about the nature or extent of your disability.
At the Hotel
Your service animal must always be under your control. This means it should have a harness, leash, or other tether unless you cannot do so because of your disability or if such would interfere with your service animal’s ability to work or perform tasks. If you cannot use a harness, leash, or other tether, you must be able to control your service animal by other means, such as voice control or signals. Outside of this, the ADA does not require your service animal to wear anything else, such as a vest or ID tag.
You cannot leave your service animal behind in the hotel while you are out. Hotels are not responsible for the care or supervision of your service animal. They can charge you for any damage your service animal causes to your room. But they cannot charge you for cleaning any hair or dander your service animal sheds.
Exceptions
Hotels may ask that your service animal be removed if it is out of control or not housebroken. If your service animal is removed, the hotel must still allow you to stay without it.
If you believe you have been discriminated against by a hotel because of your service animal, you can file a complaint with the Department of Justice or file a private lawsuit in federal court charging the hotel with discrimination under the ADA.
Know Your Rights and Plan Ahead
Whether you are traveling with a pet, emotional support animal, or service animal, it is important to know your rights. It is also a good idea to inform your airline and/or hotel ahead of time that you will be bringing an animal with you and verify their individual policies.
