By BJ Adkins, Founder, Animal-Angels Foundation

Before I had my service dog, I didn’t go out.

I have PTSD from military sexual trauma. After I came home, crowds became impossible. The VA waiting room was impossible. Going to the grocery store was impossible. I stayed home. That was the shape of my life until I had a dog trained to be at my side.

His name was Wilson. He was professionally trained, the way every legitimate service animal is supposed to be. He changed everything. I could go to appointments. I could be in public. I could function in the parts of life that other people don’t think twice about.

I lost him in 2019. I haven’t been able to replace him. The wait for a trained service dog is four years on the low end, and that’s if you can get on a list at all. So like a lot of veterans, I rely on emotional support animals now. Seven of them, technically. They are the difference between a life I can live and a life I can’t.

This morning, the New York Times reported that the Department of Housing and Urban Development is circulating an internal memo that would dramatically narrow who counts.

What HUD Is Doing

Under the new policy, emotional support animals would be largely excluded from Fair Housing Act protections. Service animals would face tighter scrutiny too. HUD’s framing is that an entire industry has emerged to convert pets into emotional support animals, and that ESA accommodation requests for untrained animals are not presumptively reasonable.

Some of that is true. There is a whole online industry selling ESA certificates for $50. People with healthy bank accounts and no disability have used the system to dodge pet rent and pet deposits. That abuse is real, and the legitimate need cases have been paying the social credibility cost for years.

But the policy response is a blunt instrument, and blunt instruments do not hit the people they aim at. They hit the people who can’t fight back.

Who Actually Gets Hit

The people who lose ESA protections under this memo are not the ones with the $50 certificates. The certificate mill customers will find another workaround. They always do.

The people who lose are the veterans with combat PTSD whose dogs wake them out of flashbacks at 3 a.m. The veterans whose dogs are the reason they get out of bed. The veterans on the edge whose dogs are the reason they are still alive.

Veterans are dying by suicide at a rate of 17.6 per day according to the VA’s 2024 National Veteran Suicide Prevention Annual Report. Service dogs are a documented intervention. A 2024 NIH-funded clinical trial published in JAMA Network Open, run by Maggie O’Haire at Purdue in partnership with K9s For Warriors, found that veterans paired with service dogs had 66 percent lower odds of a PTSD diagnosis at follow-up. Suicidality in the service dog group dropped from 55 percent at baseline to 35 percent. The wait-listed control group dropped 1 percent. K9s For Warriors reports a suicide mortality rate under 1 percent among program graduates.

This is not sentiment. It is a clinical trial. The dogs are doing measurable work.

The people who lose are also the disabled tenants on fixed income whose ESAs are not a luxury, not a workaround, not a scam. They are the difference between staying housed and not.

The people who lose are the families on a service dog waitlist who got a dog from a shelter to bridge the gap.

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And the Landlords Lose Too

Here is the part most of the policy coverage on this memo is missing.

The property and rental industry is already struggling. National vacancy is running 6.9 percent per the Pet-Inclusive Housing Initiative’s market analysis. Concessions on rents are at 37 percent, meaning most landlords are giving away the equivalent of a month or more of rent just to get tenants in the door. Turnover is expensive. The Management Group, a property company that wrote a case study with PIHI and won the 2025 Pets and Housing Award, puts the cost of a single tenant turnover at $3,000 to $5,000 depending on the market.

A tenant who loses ESA accommodation under this memo and can’t fight it is a tenant who was paying rent on time. Most ESA tenants are. The landlord evicts them, eats the turnover cost, and goes back into a 37 percent concessions market to find a replacement who may or may not stay.
The pet-inclusive housing data already shows that lower vacancy, longer tenancy, and stronger renewal rates correlate with pet-inclusive policies. The Management Group hit 80 percent renewal under their pet-inclusive model. PIHI’s damage data shows 74.7 percent of pet-inclusive units had zero pet damage at move-out, and of the rest, 88 percent of claims were under $250.

This memo is going to force landlords who would have accommodated into the eviction-and-turnover cycle, and it is going to do it under the framing of protecting them from fraud. That is not protection. That is making their problem worse.

The Downstream Cost

I run a prevention-first animal welfare organization in Central Alabama. The Bridge program at Animal-Angels Foundation exists because housing is the number one or number two driver of pet surrender, depending on whose data you pull. Lose housing, lose the pet.

When this memo takes effect, here is what will happen on the shelter intake side. ESA tenants who can’t fight an accommodation denial will be evicted or pressured out of their housing. They will choose between losing their home and losing their animal. Some will choose the animal. Most will not be able to.

The animal will end up in a shelter that was already overwhelmed. The person will end up in a worse housing situation, often without the support that kept them stable. And in the case of veterans with PTSD, sometimes the person will not survive the loss.

This is the math nobody at HUD is doing.

The Fix They Did Not Pick

The legitimate ESA fraud problem is solvable without burning down protections for people who need them. The certificate mills could be regulated. The accommodation process could require a treating clinician’s documentation with timeframes that do not punish people who can’t get a same-week appointment. The protections could be tightened around the abuse and preserved around the need.

That is not what this memo does. This memo treats every ESA accommodation request as suspect until proven otherwise, which functionally means the people who can’t pay a lawyer to prove it lose by default.

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Final Thoughts

Housing policy is animal welfare policy. The same families who lose ESA protections are the families who end up at the shelter door. I built the Bridge program to catch them before they get there. I cannot catch them all.

If you’re a housing provider reading this, the data on pet-inclusive housing is clear. Lower vacancy, longer tenancy, better outcomes. The Pet-Inclusive Housing Initiative has been publishing that case for years.
If you’re a fellow veteran, please don’t read this and decide it’s too much to think about. The advocacy groups are organizing. The legal challenges are coming. Your voice matters.
And if you’re a legislator or a federal employee who can read a memo and tell the difference between a real problem and a wrong fix, this is the moment.

I own my home. I bought it, which means I do not have to worry about whether I am allowed to have my animals, how many I can have, or what the policy is. I was in a position where I could do that. Most veterans and most low-income people with disabilities are not.

If I were in that position and it came down to my housing or my animal, I would be choosing my animal. I would be out on the streets, or I would be a suicide statistic. That is what is at stake for the people this memo hits.

I had a service dog named Wilson. I lost him in 2019. Seven dogs sleep in my house tonight, and they are the reason I can do this work. They are not a loophole. They are not a scam. They are the reason I am still here.

Sources

U.S. Department of Veterans Affairs. 2024 National Veteran Suicide Prevention Annual Report. mentalhealth.va.gov/suicide_prevention/data.asp

Leighton, S. C., et al. (2024). Service Dogs for Veterans and Military Members With Posttraumatic Stress Disorder. JAMA Network Open. NIH-funded clinical trial. Conducted by the O’Haire lab, Purdue University College of Veterinary Medicine, in partnership with K9s For Warriors.

Pet-Inclusive Housing Initiative (PIHI). Pets and Housing Data Reports including 2024 market analysis (vacancy, concessions) and damage outcome data. petsandhousing.org

The Management Group case study with PIHI. 2025 Pets and Housing Award winner. Turnover cost and renewal rate data.

New York Times. HUD Narrows Definition of Assistance Animal in Housing.

I'm a Veteran. I Had a Service Dog. Here's…