— Larry W. – San Diego, CA
ANSWER: The ADA Title III Regulations do not define emotional support animals as service animals and emotional support, well-being, comfort or companionship do not constitute work or tasks for the purposes of this definition. There does appear to be an exception for service animals in relation to PTSD, in guidance issued by the Department of Justice that broadens the definition of work that some may interpret as emotional support. Also, emotional support animals may nevertheless qualify as permitted reasonable accommodations for persons with disabilities under the FHAct. The ACAA and housing facilities must apply reasonable accommodation requirements of the FHAct to determine whether to allow a particular animal needed by a person with a disability into housing. They may not use the ADA definition as a justification for reducing their FHAct obligations.