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Service Animals in Park Housing

Introduction

You manage the seasonal housing in your park. A new employee is moving in and you see they have a dog wearing a vest with a “Service Dog” patch on it. The park’s policy is to not allow pets in park housing. Your mind swims with the possible outcomes of dealing with this situation.  Luckily there is guidance to help you handle it.

This article gives you an overview of the differences between service animals and comfort animals and how specific situations related to park housing might be handled. But when handling a real-life situation, be sure to review the Housing policy and NPS Housing Guidance-Service and Emotional Support Animals within Employee Housing.

Service Animals vs Comfort Animals

A Siberian Husky wearing a service dog vest sits on the floor of an office.
Photo Credit: NPS. Luna the service dog at work at Mather Training Center.

A service animal means any dog* that is individually trained to do work or perform tasks for the benefit of an individual with a disability, including a physical, sensory, psychiatric, intellectual, or other mental disability. The ability for someone to live with their service dog is considered a civil right.

A comfort animal can be any animal such as a cat, a bird, or a snake. The other main difference is that they have not been trained to perform a specific task. A comfort animal may be inherent to the Employee’s emotional health, and if you decide to allow it in park housing, it is still required to be housebroken and behave. The employee is responsible for any damage it may cause.

Here’s some examples of how service animals differ from comfort animals.

Service Animal At a Glance Comfort Animal at a Glance
  • Must be a dog (or in certain cases a miniature horse). There is no limit to size or breed.
  • Must perform a task related to the person’s disability
  • Can be removed for behavioral reasons.

They are not required to:

  • Be certified
  • Be professionally trained
  • Wear vest harness or other identifiers
  • Can be any animal
  • Provides a benefit to a person’s well-being
  • Can be removed for behavioral reasons
Examples of Tasks
  • Licks and nuzzles to calm anxiety
  • Stands in front of me and forces me to sit when I am having an anxiety attack
  • Searches area to provide all clear
  • Orientation and mobility for the blind
  • Opens doors
  • Picks things up off the ground
  • Notifies of sounds
  • Alerts to seizures or blood sugar
  • Helps with support and gait
Examples of Personal Benefit
  • Petting her calms me down.
  • His presence makes me feel safe.
  • She makes me feel less alone.
  • His affection makes me feel less depressed.

Which Is It?

Some service animals are obvious, but when it’s not obvious, you can ask a couple of questions:

  • Is the animal required because of a disability?
  • What work or tasks is the animal trained to perform?

Scenarios

Now that you have an idea of how service animals differ from comfort animals, here’s some examples of how to deal with specific situations that might arise.

Scenario 1–Your Park Allows Pets in Park Housing

Boom. You’re done. No action required for service or comfort animals. You’re probably not here because you’ve dealt with this situation, though.

The rest of these scenarios are for parks that don’t allow pets in park housing.

Scenario 2–An Employee has an Obvious Service Dog

An employee with a visual impairment brings his dog to work because it helps him navigate hallways, offices, and parking lots. You don’t need to ask questions or get documentation. When he moves into park housing, work together to provide appropriate accommodations. It’s their civil right. You must allow the dog in park housing.

Scenario 3–Not an Obvious Service Dog

An employee with no “obvious” disability wants to bring a service dog into park housing. Here’s how the conversation might go:

You: “Is the animal required because of a disability?”

 

Employee: “Yes it is required.”

 

You: “What work or tasks is the animal trained to perform?”

 

Employee: “He licks my hand when he senses I may have a seizure so I can take needed precautions.”

The dog is considered a service dog because it has been trained to do a specific task, so you will allow the employee to have the dog in park housing.

Service animals are protected under civil rights law. Rights of the person with a service animal trump preferences or needs of other residents. The circumstances to deny service animals are extremely rare. In fact you must prove a FUNDAMENTAL ALTERATION will result from accommodating the animal. Service animals must be allowed in housing regardless of Required Occupancy (RO) or permitted status.

Scenario 4– Employee has Dog as a Reasonable Accommodation in the Workplace (DO16)

An employee is moving into shared park housing. She is a veteran with PTSD and her dog calms her when she is stressed so she has been provided a reasonable accommodation to have the dog with her in the workplace.

Workplace reasonable accommodation is automatically extended to housing regardless of RO or permitted status. This reasonable accommodation trumps the preferences and needs of other residents. This could get tricky if the house mate has allergies and housing options are limited. But the bottom line is — Treat a comfort animal as a workplace reasonable accommodation like you would treat a service animal.

Scenario 5– Employee Doesn’t have Workplace Accommodation

An employee wants to have a cat in her park housing. She struggles with depression and the cat provides her with comfort and purpose. This isn’t a service animal so you start the process to determine if her request will be approved or denied. Read on for the process.

Process

The process for determining if the animal will be permitted is outlined in detail in the NPS Housing Guidance-Service and Emotional Support Animals within Employee Housing.

  1. Initiation Phase –The Employee makes the request and provides documentation to the Superintendent or their designee.
  2. Verification Phase — The Superintendent or designee works with the Park Housing Officer, and possibly the Regional HR Manager, to verify documentation and ensure that eight determining criteria are met.
  3. Decision Phase — The Superintendent provides a written decision to the requester within 20 days from the date of request. If denied, the requester has the right to appeal the decision. The Housing Manager’s Guide includes a Decision Documentation Template.

Other Common Issues

Roommates

The right of the person with the animal trumps a roommate’s desire not to room with the animal – the roommate must accommodate UNLESS, the roommate has a religious or medical reason to not be housed with an animal – mutual accommodation must be reached.

Additional Guidance

  • All of this guidance extends to family members with animals.
  • Veterinarian certification can be required.
  • Tenants can be required to pay for damage caused by animal.
  • Service animals in training and “retired” service animals are considered pets.

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