Autism Service Dogs

I just got off the phone with Horizon Air's customer service. I was trying to book a flight to Los Angeles, and was having trouble arranging for accommodative seating.

The FAA regulations state that a service animal may not sit in an emergency exit row. Unfortunately, the planes Horizon operates in this particular market don't have bulkhead or first-class seats; instead, the forward-most seats are coach-class emergency exit rows, so Glindy and I may not sit there. This would seem to technically violate 14 CFR 382.38(a)(3), but I'm not sure how much hay one could make of that.

The Air Carrier Access Act also says that an airline must either block seats or provide priority seating for disabled passengers, but the ways they can go about it are often unfriendly. Horizon handles this situation by requiring disabled passengers to check in early, and ask the ticketing or gate agents to arrange for blocking or rearrangement of seats. This method may meet the requirements of the seating assignments section (14 CFR 382.38(b)), but leaves some edge cases where one is likely to have to involve a Complaints Resolution Official (14 CFR 382.65).

What this means in practice is that Horizon will do its best, but it is certainly possible to be bumped from a flight under certain circumstances. For example, if the flight is completely full and no one is willing to share foot-space with your dog, you might be out of luck, as a carrier isn't required to furnish more than one seat per ticket (14 CFR 382.38(i)) or bump other passengers to provide an accommodation (14 CFR 382.38(h)).

Whether or not Horizon is meeting the requirement to adequately disclose limitations on accommodation (14 CFR 382.45) remains an open question in my mind, but Horizon is unfortunately within the law in how they choose to assign seats in this case.

In the end, I cancelled my Horizon Air reservation, and booked on Southwest instead, since Southwest does provide bulkhead seats to disabled passengers. In addition, Southwest's reservation system now allows passengers to indicate, at the time of booking, that they will be travelling with either a service dog or emotional support animal. This is a huge step forward, in my opinion; it certainly saves the hassle of having to contact the airlines after making the reservation to have the ticket annotated.

Well, Horizon's loss was Southwest's gain. I would prefer having assigned seats on a plusher plane such as those Horizon Air operates, but I vastly prefer Southwest's accommodation practices.