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Recently, the Department of Transportation (DOT) overhauled the rules regarding assistance animals on planes. The good news? Both service animals and psychiatric service animals (PSDs for short) are still protected and therefore are allowed to accompany their handlers on the plane — as long as they abide by the new processes.
The bad news for some travelers? Emotional support animals are no longer allowed on planes. Some airlines still allow pets (meaning non-service animals) on planes, but how they are treated varies drastically from how a service animal is treated.
This guide will cover how the DOT process has changed, who is eligible to fly with a service animal, all the paperwork requirements for each airline, and more. So whether or not you’ve flown with a service animal before, read on for the current guidelines.
What Is a Service Animal?
In early 2021, the DOT put into place new guidance on service animals, which, among other things, specifically defined a service animal as “a dog that is individually trained to do work or perform tasks for the benefit of a person with a disability” — notably including psychiatric and mental disabilities, which had previously required extra steps for qualification.
Now, “service animal” does not cover emotional support animals or animals other than dogs.
The primary difference between a service dog and a pet/emotional support animal is that a service dog must be specifically trained to perform tasksdirectly related to the handler’s disability. Even a service dog in training is not considered a full-fledged service dog until it has completed its training.
There’s no official list of these tasks, but we’ve compiled a sample of some of the primary tasks service dogs provide. These tasks are separated between those with physical and psychiatric/mental disabilities.
Physical Disability Tasks:
Alerting the owner of an oncoming seizure or a rise/drop in blood sugar levels
Carrying bags and other objects
Guiding the visually or hearing impaired
Opening and closing doors and drawers
Pressing buttons (such as in an elevator)
Providing stability while using stairs or navigating hazardous areas
Pulling/guiding a wheelchair
Psychiatric/Mental Disability Tasks:
Acting as a physical buffer in crowded areas
Interrupting or reorienting the handler during panic/anxiety attacks
Interrupting repetitive/damaging behaviors
Reminding the owner to take their medication
Using various methods to calm the handler
In addition to completing these tasks, a service dog should also be able to pass a “public access test” as well. This ensures they can focus on the handler and their duties even in potentially stressful environments like airports.
Dogs not performing tasks related to the handler’s disability are considered pets and subject to each airline’s rules and regulations regarding traveling with pets.
What Is a “Disability”?
Under the DOT’s rules and the Air Carrier Access Act, a disability is a physical or mental impairment substantially limiting one or more major life activities. “Major life activities” include working, sleeping, learning, and other routines.
This definition covers physical impairments such as limited mobility or vision impairment and those with mental impairments. The DOT’s new rules also specifically mention “psychiatric, intellectual, or other mental” disabilities. Psychiatric service dogs are commonly used by people with conditions such as severe depression, anxiety, PTSD, and autism.
Training and Certifying a Service Dog
Earlier, we discussed a public access test. This isn’t a specific test conducted by any particular organization but rather a way to ensure your service dog can perform at the level necessary for the handler.
Aservice dog does not need to be trained by any specific third-party trainer, school, or organization. The DOT notes that “service animal users are free to train their own dogs to perform a task or function for them.”
Any registrations and/or certifications for service dogs are always optional and are not mandatory.
There are some items service dog handlers can use to signal to members of the public that a service dog is on duty. These include a harness, tag, or vest, or you may have a certificate or ID card.
If your disability is not readily apparent, these signals may protect you from intrusive questioning by TSA or airline staff. Just remember, having one of these items isn’t enough to qualify your dog as a service dog — it’s just 1 factor the DOT says airlines can use to help determine whether a dog can be considered a service dog. We’ll discuss all of these in more detail below.
What About Size or Breed-specific Considerations?
The DOT doesn’t set a weight limit for service dogs but notes that airlines can require that a service animal fit within the handler’s foot space or on the passenger’s lap. Most importantly, the DOT recognizes all types of dogs as service dogs and does not allow airlines to set restrictions based on specific breeds.
If your service animal is larger than can comfortably be accommodated in your seat, the new rules require the airline to move the owner and the service dog to another seat within the same class of service, if possible (e.g., to a row with an open seat or bulkhead seating).
If no accommodations can be made, the airline must offer the opportunity to transport the service dog in the cargo hold free of charge — not ideal — or travel on a later flight.
Can I Travel With More Than 1 Service Dog?
You can travel with 2 service dogs, according to the DOT’s new guidelines. Each dog may serve a different purpose but must still fit in the handler’s foot space or lap.
This can make it tough for people with 2 large service dogs, so it might be worth taking additional steps, such as purchasing an additional ticket, to ensure service dogs can be accommodated without the risk of them having to travel in the cargo hold — or being bumped from multiple flights.
This form states that your service dog will either:
Not need to relieve itself while on the flight
Can relieve itself during the flight without creating a health or sanitation issue (the example it gives is the use of a doggie diaper)
These are both federal forms, so as the DOT states, it is considered a federal crime to “make materially false, fictitious, or fraudulent statements, entries, or representations knowingly and willfully” when completing either.
Service Dog Verification by Airline
Since there are no official organizations or forms to certify your dog as a service dog, how does an airline confirm that your dog is indeed a service dog?
In addition to reviewing the DOT forms, the DOT gives airlines 3 ways to determine whether someone is traveling with a genuine service animal:
Ask whether the service dog must accompany you because of a disability and what specific tasks the animal has been trained to perform. However, for privacy reasons, the airline cannot ask specific questions about your disability.
Observe the behavior of the service dog. This includes observing the temperament of the service dog and its interaction with you and other passengers.
Look at any harness, vest, or tags your service dog may be wearing, or any certificate.
While all airlines are required to accommodate service dogs, each airline may handle the process slightly differently. For example, some airlines have a link on their website to submit the form directly, but other airlines only accept the forms by email. Here are some handy links for you to look at:
These DOT rules generally only cover domestic travel, but a few places, like international destinations and Hawaii, impose additional restrictions.
Hawaii requires that service animals travel with a “valid animal health certificate” to enter from other U.S. states. It must be from your dog’s veterinarian, dated within 14 days of arrival. The State of Hawaii notes that service animals are exempt from any quarantine requirements but “must complete pre-shipment requirements including having a current rabies vaccination, passing an OIE-FAVN rabies blood test before arrival in Hawaii with > 0.5 IU/ml and certification.”
Be aware that not all countries accept animals, and not all countries protect service animals like they are in the U.S. You are ultimately responsible for ensuring you comply with all requirements and complete any documents necessary to travel with animals to your destination country.
What To Expect at the Airport
By the time you arrive at the airport, you’ve probably already submitted the required DOT Transportation Form (remember, you must submit this at least 48 hours before your flight).
But if you booked your flight less than 48 hours before, bring it along and be ready to submit it to your airline at the airport. Either way, it’s good to keep a paper or digital copy handy if you are asked to provide it again.
If you travel with a service dog, it’s a good idea to arrive earlier than usual. Confirm at your airline’s check-in counter to ensure they have your DOT Transportation Form. Airline staff may also observe your service dog at this point to ensure it is well-behaved and under your control.
Staff may inspect your dog’s ID cards, leash, tags, etc., and will ensure that it is harnessed (it should remain so at the airport and on your flight).
As we noted earlier, airport workers and airline staff can verify you have a service dog by asking 2 questions:
Is the service dog required because of a disability?
What work or task has the dog been trained to perform?
Per the DOT, these are the only questions that you are allowed to be asked. You have a right to privacy as a service dog owner.
Another anxiety-inducing part of airport travel is taking your service dog through TSA security checkpoints. The good news is that TSA will NEVER separate you from your service animal.
TSA also has a handy FAQ section to help ease your concerns.
Airport Relief Areas
A common concern for service dog owners is having access to pet relief areas. The spaces vary in quality based on the airport, but the good news is that providing access to a pet-relief area (both inside and outside of the terminal) is a requirement.
These Service Animal Relief Areas (or SARAs) have minimum requirements set forth by the FAA and must include space to accommodate a wheelchair, and other sanitation standards.
If you are having trouble locating a SARA, find any airport or airline staff member to ask them where it’s located.
While you’re on the plane, DOT states that the airline can require the service dog to be harnessed or otherwise restrained — even if this might interfere with the service animal’s work. Note that this is a stricter approach than the ADA, which states that a disabled person can use voice commands or other signals where appropriate.
In addition, as previously noted, all service dogs must be well-behaved during the flight, fit in the space allocated to them, and not be disruptive. This usually translates to the dog not barking, jumping on others, acting aggressively, or relieving itself in the open.
Ultimately, if the service dog causes any damage to the airplane cabin, the owner is responsible for the damages and can even be banned from future flights.
Reasons Airlines Can Ban or Deny Boarding for a Service Dog
Safety Requirement Violations: There may be instances where the service dog is too big or cannot otherwise be accommodated on a flight. This may result in a denial of boarding, but you and your service dog can typically be bumped to a later flight.
Direct Health and Safety Threats: Airlines must make an “individualized assessment” of the service dog in question solely based on their interactions at the airport and on the plane. The dog’s breed cannot be the determining factor for this decision.
Cabin or Gate Disruption: If an airline staff member observes your service dog’s lack of training, it can be denied boarding. The airline must also consider mitigating measures (such as using a muzzle to silence a barking dog).
Health and Safety Regulations: Transporting service animals is prohibited in some territories or countries, or you may be required to comply with additional health and safety regulations (such as certain vaccinations). If you do not comply, your service dog may be denied boarding.
Insufficient Documentation: This refers to the same DOT transport and relief forms (for longer flights) discussed above. All documentation must be submitted before boarding the flight.
Note that if your service dog cannot be accommodated for any reason, any airline must provide a written statement describing those reasons within 10 days.
If You Encounter Problems
When traveling with your service dog, if you believe your rights under the Air Carrier Access Act are being violated, ask to speak with a Complaints Resolution Official (or CRO). Per the DOT, a CRO “is the airline’s expert on disability-related issues in air travel.”
Airlines are required to make a CRO available to you in person at the airport or by telephone — at no cost to you.
You can also file a consumer complaint directly with the DOT online or via phone at 202-366-2220 Monday through Friday between 8:30 a.m. and 5 p.m. EST.
Helpful Tips for Traveling With a Service Animal
Before you head to the airport, here are a few key things to remember.
Health and Safety
Depending on your destination, it may be necessary to visit your vet before your travel date to ensure your dog is healthy and up-to-date on vaccinations. At a minimum, the DOT’s transport form will require you to certify your service dog is vaccinated and ask for your vet’s contact information.
Don’t forget your service dog’s vest, tags, ID card, harness, and other accessories. In addition, a leash or harness will help you navigate a busy airport and crowded airplane cabin, and the airline can also insist that your service dog is properly restrained and under your control at all times.
Don’t forget to pack everything your service dog might need for your trip, including medication, food, treats, water, dishes, and other grooming products.
Food and Drink
Limit the food and drink you provide your service dog before a flight, as they may not have access to relief areas for quite some time. In addition, don’t forget to use the service animal relief areas before boarding, if possible.
It never hurts to arrive a few hours early at the airport when traveling with a service dog. This can help relieve some of the anxiety, especially if there are unexpected obstacles like a long security line or a gate change.
Whether you’re an experienced service dog owner who has flown with it for years or planning your first flight with your service dog, we hope you found this guide useful, especially in light of the recent DOT changes.
Refer to this guide often to remind yourself what to expect when flying with your service dog, including all of the required documentation, and to ensure you’re educated about all of the accommodations you and your dog are entitled to receive — both at the airport and in the air.
Featured Image Credit: 24K-Production via Adobe Stock
Frequently Asked Questions
Are service dogs allowed on airplanes?
Yes, service animals are required to be accommodated on airplanes (and on all airlines) that operate within the U.S., per the U.S. Department of Transportation. There are guidelines related to where they can sit and how they must behave while on the plane. There are no size or breed restrictions for service dogs. Note that since January 2021, these protections do not extend to emotional support animals.
Do service animals fly free?
Yes, service animals fly for free, permitted they meet the requirements of being a service animal. We’ve listed these all in the article above. If they don’t, they will be required to pay a pet fee (if the airline accepts pets) or be denied boarding.
Are emotional support animals considered service dogs?
No, animals whose sole function is to provide comfort or emotional support do not qualify as service animals per the Department of Transportation. This brought the DOT into alignment with the Americans with Disabilities Act. This change went into effect in January 2021.
What proof do airlines need for service dogs?
There are a number of ways that an airline can determine if your dog is a service dog. In addition to reviewing your required DOT forms, these methods include:
Asking the service dog’s owner if the animal is required to accompany the passenger because of a disability and what work they are required to perform
Looking at the physical indicators (such as a harness or ID) and ensuring the animal is leashed
Observing the animal’s behavior and ensuring they are under your control
Does a service dog count as a carry-on?
No, a trained service dog is not considered a carry-on and does not count toward your carry-on allotment. Service dogs are required to be accommodated on all flights within the U.S. Also, your service dog does not need to travel in a carrier in the cabin.
After having “non-rev” privileges with Southwest Airlines, Christy dove into the world of points and miles so she could continue traveling for free. Her other passion is personal finance, and is a certified CPA.