Service Animals and the ACAA

Published November 23, 2021

The Air Carrier Access Act (ACAA) provides protections for people with disabilities that need to travel with their service animals. The ACAA defines a service animal as a dog, of any breed, that is individually trained to perform tasks for the benefit of a handler with a disability. Service animals can provide support to a wide range of people with physical, psychiatric, or other disabilities.

How do airlines verify if an animal is a service animal?

Airlines can determine whether an animal is a service animal or pet by observing the behavior of the animal, looking for physical indicators such as a vest or harness, or asking two approved questions.

The ACAA allows airlines to ask the traveler if the animal is required to accompany them because of a disability and what work or tasks the animal has been trained to perform. These questions may sound familiar, as they are also the two questions approved under the Americans with Disabilities Act (ADA).

What paperwork can airlines request from service dog handlers?

Airlines can now require standardized Department Of Transportation (DOT) forms to be completed prior to boarding. Most airlines make these forms available online. The ACAA allows airlines to require the form to be filed at least 48 hours before the flight time if the handler has made the flight reservations by that time. Airlines do not need to accept late or last-minute forms if bookings were made less than 48 hours before takeoff.

The DOT form asks basic questions about the service animal and requests that the handler attests to the animal’s health, behavior, and training. It collects information on the dog’s veterinarian, past behavior, and ability to behave professionally on the flight.

Do airlines always have to accept service animals?

Airlines are generally required to accommodate service animal handlers, but there are a couple of scenarios in which airlines are allowed to deny a service animal:

  • Safety Concerns: If the animal is too large or heavy to be accommodated in the cabin or the animal’s presence poses a direct threat to the health or safety of others. Another passenger’s allergy is typically not classified as a direct threat. Airlines should instead seat any passengers with dog allergies away from the service dogs on board the flight. A serious bite history or a display of aggressive behavior at the airport or during boarding may qualify as a safety threat.
  • Disruptive behavior: If the animal causes a significant disruption in the cabin or at airport gate areas, even if said behavior is not aggressive, they may be denied transport by the airline.
  • Destination requirements: If the animal is prohibited from entering a U.S. territory or foreign country or does not meet local health guidelines, the animal may not be allowed on the flight. Always double-check health requirements at your destination if traveling outside the continental United States, as some territories or countries may deny your animal or require them to be quarantined upon arrival if appropriate health records have not been provided.

Airlines are no longer required to transport emotional support animals, as of the December 2020 ACAA revision. ESAs are support animals that are not task-trained, but provide emotional support to travelers with disabilities. Psychiatric service animals, who are task-trained to provide support for a mental health condition, are still covered under the ACAA.

Where do service animals sit on planes?

The ACAA does allow airlines to require a service animal to fit within its handler’s foot space on the aircraft. Often service animal handlers will sit in the bulkhead seats or other seating with extra foot space to provide more room for their animals. Airlines may allow small service animals to sit in their handler’s lap.

Why accommodating service animals is important

People with disabilities have just as much of a need and right to travel as anyone else. For people that use service animals, the animal is a key piece of medical equipment that helps them maintain safety and independence while traveling and completing other life activities.

If you see someone traveling with a service animal, be respectful and do not distract the animal. Transportation providers should also do their due diligence to provide a safe and accessible travel experience to all people with disabilities, including those traveling with service animals.

 

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