Animal Welfare Professionals

The New York Times reported today that HUD is circulating an internal memo that would dramatically narrow Fair Housing Act protections for assistance animals. Emotional support animals would be largely excluded. Service animals would face tighter scrutiny too. The justification HUD is using is the ESA certificate mill industry, which is real. The policy response is a blunt instrument.

I want to flag what this means for shelter intake, because most of the policy coverage I have seen so far is missing it.

Housing is the number one or number two driver of pet surrender depending on whose data you pull. Pizano's Go-To Guide, Best Friends data, PIHI data all converge here. Lose housing, lose the pet. The same families who lose ESA accommodation under this memo are the families who end up at the shelter door.

The people who lose are not the $50 certificate buyers. The certificate mill customers will find a workaround. They always do. The people who lose are the veterans with combat PTSD, the disabled tenants on fixed income, and the people on multi-year service dog waitlists who got a shelter dog to bridge the gap.

On what is at stake clinically: a 2024 NIH-funded clinical trial published in JAMA Network Open (O'Haire lab at Purdue in partnership with K9s For Warriors) found that suicidality in the service-dog group dropped from 55 percent at baseline to 35 percent at follow-up. The wait-listed control group dropped 1 percent. K9s For Warriors reports a suicide mortality rate under 1 percent among program graduates. The VA's 2024 Annual Report puts veteran suicide at 17.6 per day. This is documented.

One more angle the field should track. This memo also hurts the property and rental industry. National vacancy is at 6.9 percent. Concessions on rents are running 37 percent. Turnover costs $3,000 to $5,000 per unit per The Management Group case study with PIHI. ESA tenants who get pushed out under this memo were paying rent on time. Landlords lose stable tenants and absorb the turnover cost into a market already giving away a month of rent in concessions. The coalition argument here is bigger than just animal welfare. Property managers have a self-interest reason to push back too.

Here is what I am asking the field:

Are any of you tracking call volume tied to housing-and-pet-loss scenarios? Specifically an intake reason code for lost-housing-because-of-pet, ESA-accommodation-denied, or breed-restriction-eviction?

If you are, I would love to compare notes. If you are not, this might be the moment to add it. The data we capture in the next six months is going to determine whether this memo is treated as a housing policy story or as an animal welfare story or as a property market story.

We are tracking it on the Pet Help Desk side at Animal-Angels Foundation through our CallIntake structure. Happy to share the field setup if useful.

For context on why this matters to me personally as well as professionally: I am a disabled veteran with PTSD from military sexual trauma. I had a professionally trained service dog named Wilson. I lost him in 2019. I rely on emotional support animals now. So the downstream cost this memo creates is something I can see from both sides.

The cost lands on us. Let's make sure we are capturing it.

#AdmissionsandIntake(includingIntake-to-placement)
#CaseManagement*
#LawsandPublicPolicy

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Join The Shift To Prevention.

BJ Adkins
Founder/Director
Animal-Angels Foundation
Pinson, AL
calendy.com/animal-angels
bjadkins@animal-angels.org
animal-angelsfoundation.org
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BJ -

This is the analysis the policy coverage is missing. The memo treats the mills as the rationale for narrowing the doctrine. But the mill customers aren't the ones who lose accommodation. They route around it. The people who lose are the populations you named: veterans with PTSD, disabled tenants on fixed income, service-dog waitlist bridges. The cost lands on shelter intake and on the tenants HUD is supposed to be protecting.

I litigate the mill side. Stevens v. Tinner (permanent injunction, Broward) and Stevens v. Wood (FDUTPA, Wellness Wag platform, filed) are on the record. Two civil RICO cases against national operators are in preparation. My read on Turner lines up with yours from the opposite direction. The mills are a real problem. The memo isn't an enforcement response to them. It's a doctrinal rollback using documented fraud as cover. Six years of regulatory tolerance, then a rule change instead of enforcement.

The coalition argument at the end of your memo is the piece the housing-policy reporters I've talked to don't have yet. Property managers with self-interest in stable ESA tenancies, vacancy at 6.9%, turnover at $3–5K per unit. Landlords aren't supposed to be on the disability-rights side of this fight. The economics put a subset of them there. That's a story.

Worth comparing notes. The litigation lane and the shelter-intake data lane don't usually meet. They should on this one. The mills get sued. The doctrine gets defended. Two fronts, same fight.

Chaz Stevens, MSc, CLE Faculty
research.revolt.training

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Chaz Stevens
Founder
REVOLT Training
FL
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