FlyersRights.org as the largest nonprofit airline passenger organization with 60,000 member supporters has been studying the issue of animals on planes for several years.

Toward that end we sent observers to a DOT advisory committee of stakeholders (airlines, flight attendants, service animal trainers, disability advocates) which attempted (unsuccessfully) to do a negotiated rulemaking several years ago.

More recently, in 2018, we conducted a survey of our members which had 750 respondents (see results at https://arrowiq.typeform.com/report/TYpcZz/kH8UcPu8nWmrgzrU ).

One of our board members is a former traveling doctor of veterinary medicine with vast experience. Some of our members have traveled with emotional support animals, and many have pets that have traveled by air.

Finally, as operating the only toll-free hotline for passenger complaints and problems since 2008, we receive calls from passengers with allergies, phobias and other concerns regarding animals in air travel.

Accordingly, based on this extensive experience, FlyersRights.org supports tightening the regulations that currently permit nearly anyone to obtain an emotional support certificate to travel with a pet for free.

We affirm the important protections of the Americans with Disabilities Act and the Air Carrier Access Act, with due regard for non-disabled passengers including those with animal allergies or phobias.

We also support the expansion of facilities by airlines to transport pets and service animals in humane and cost-effective ways. The No. 1 priority for regulations should be the health, safety and convenience of human passengers, with due regard for humane treatment of animals.

With regard to the specific topics contained in the notice of proposed rulemaking, our comments are as follows:

1. Psychiatric service animals should be treated the same as other service animals provided that the passenger has a letter from a bona fide licensed mental health professional such as a psychiatrist or psychologist.

2. There should be a distinction between PSAs and emotional service animals, with airlines allowed to ban ESAs where they are not trained to do any specific tasks and are very often pets that are traveling free in the cabin but could otherwise be accommodated by airlines.

3. The use of pet carriers is appropriate for small dogs under 10 pounds but should not be required for larger animals or in all cases as this defeats the purpose and function of the animal for service and emotional support to the passenger. And it will often be impossible to accommodate larger animals without special space allocation or allowance for safe egress.

4. Animals serving as PSAs or ESAs in the cabin should be limited to dogs. A high proportion of passengers (about 10 percent according to WebMD) are allergic to cats, some to a life-threatening degree, and 5 percent to dogs. Other passengers (estimated at 13 percent) have animal phobias, commonly to dogs, snakes, rodents, insects and spiders. Other animals such as monkeys, miniature pigs or horses, birds and reptiles pose sanitary as well as allergy and phobia concerns. Cats are generally not recognized as PSAs and can be conveniently carried in carriers.

5. There should be a limit of one animal per passenger in a cabin at the discretion of the airline, but no more than two.

6. There should be an attestation that an ESA animal has been trained how to behave in public, and this should be kept on file with an airline to avoid unnecessary repetition.

7. Animals should be harnessed, leashed or otherwise tethered.

8. Large animals should not block egress, not intrude on other passengers’ space and should be limited by weight to about 80 pounds.

9. Veterinary forms should be required for any animal not confined to a carrier, including health and behavior questions, or the user should be required to provide insurance covering any damages to property or persons of $250,000 or more.

10. Passengers should have notice of requirements of foreign carriers re ESAs and PSAs.

Animal Welfare Concerns

As animals generally require relief and water every six hours or so and may become agitated or panicked if confined for long periods in close quarters with jet noises, their time in cabins should be limited to approximately three hours without special provisions. Moreover, veterinary space standards for transporting animals should not be violated. Finally, pet relief areas should be required at all large airports, within the secured zone within a few hundred yards of arrival gates.