# ESA Letter in New Britain, CT: The Bar Is 'May Be Necessary'

> New Britain rents at 54.9 percent and its city ordinance has no accommodation clause. The ESA letter request here rests on eleven words of state law.

- Source: https://supportanimal.com/blog/connecticut-emotional-support-animal/new-britain/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-20
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 75,871
- Households renting: 54.9%
- Typical pet deposit (as a pet): Capped: 2 months' rent
- Typical pet rent (as a pet): Varies by building
- Breed/weight limits common: yes
- Pet fees, deposits, and breed limits with a valid ESA letter: none (FHA reasonable accommodation)

## A town where most homes are rented, at $1,253

New Britain is Connecticut's eighth-largest municipality (75,871 people on
the 2024 Census estimate), and 15,920 of its 28,974 occupied homes are
rented. That is **54.9 percent** on the 2020-2024 American Community
Survey, against 33.5 percent across the state, and a higher renter share
than either of the towns immediately around it: West Hartford at 32.6
percent, Bristol at 35.1 percent.

Median gross rent is **$1,253**, well below the $1,488 state figure and
cheaper than every one of Connecticut's ten largest towns except Waterbury
at $1,225.

None of which is what usually goes wrong. What decides the outcome here is
narrower and more practical: what the request has to establish, what it
does not, and what a landlord is allowed to do with it.

## Eleven words that set the bar lower than most people assume

Everything rests on one clause. Section 46a-64c(a)(6)(C)(ii) defines
discrimination to include:

> "a refusal to make reasonable accommodations in rules, policies, practices
> or services, when such accommodations **may be necessary** to afford such
> person equal opportunity to use and enjoy a dwelling"

Read the verb. Not "is necessary." Not "is essential." *May be.* The
federal counterpart at 24 C.F.R. § 100.204(a) uses the same conditional,
and it is doing real work: the tenant is not asked to prove that life
without the animal would be impossible, only that the change may be needed.

The second half supplies the measure. "Equal opportunity to use and enjoy a
dwelling" is a comparison, against what a tenant without a disability gets
out of the same flat. A property manager who replies that you appear to be
coping, or that other tenants manage without an animal, has answered a
question the statute never asked.

What the statute does ask of you is that the accommodation be *reasonable*.
The federal regulation's own worked example calls an accommodation
reasonable "because it is feasible and practical under the circumstances,"
which is a workable test to apply to your own request before you send it.

## The duty attaches to the rule, not to the animal

The statute names its target: "rules, policies, practices or services." A
no-pets clause is a rule. So is a 25-pound weight cap, a breed list, a
two-animal limit, a pet-rent line on the ledger and a pet deposit on the
move-in sheet. Each of those is a policy that, left in place, produces
unequal use of the dwelling, and each is therefore the thing under
examination, not the dog.

That framing is easier to see in the federal regulation, whose second worked
example involves no animal at all: a tenant who cannot walk far asks that
one of a complex's first-come, first-served parking spaces be reserved near
his unit, and refusing is a violation. Same machinery, no pet policy in
sight.

So a leasing office answering "our policy is 25 pounds" has not answered.
The policy is the subject of the request.

## One request, one animal, one decision

The provision is written in the singular throughout ("such person," "such
accommodations"), and that is how it has to be worked. A landlord evaluates
the individual request and the individual animal in front of them. A
category answer is not an evaluation.

There is a real limit, and it is drawn the same way. Federal regulation
provides that nothing requires a dwelling to be made available to an
individual whose tenancy would constitute a direct threat to the health or
safety of others, or would result in substantial physical damage to the
property of others, 24 C.F.R. § 100.202(d). That is a finding about a
specific tenancy, resting on what has actually happened, not a reputation
attached to a breed. A landlord who reaches for it should be asked what
this animal has done.

Who counts as disabled is rarely the sticking point. Section 46a-64b(8)
defines "physical or mental disability" as including "but is not limited
to" intellectual disability under § 1-1g, physical disability under
§ 46a-51(15), and "but is not limited to, persons who have a handicap as
that term is defined in the Fair Housing Act."

## What goes in the letter, and what stays out

Two findings, and they are the only two: that you have a disability within
§ 46a-64b(8), and that the animal is needed because of it. The connection
between them is the substance. Everything else is packaging.

Useful packaging, though. Put the request in writing, date it, name your
unit, and name the rule, "an exception to the no-pets clause at paragraph
14" gives a manager something to decide, where "I have an ESA" gives them
somewhere to file it. Address it to whoever can actually say yes, ask for
the answer in writing, and keep a copy of what you sent.

Now the other half, which is where most tenants over-disclose. Federal
regulation makes it unlawful "to make an inquiry to determine whether an
applicant for a dwelling … has a handicap or to make inquiry as to the
nature or severity of a handicap of such a person": 24 C.F.R.
§ 100.202(c). The exceptions listed after it are ordinary screening
questions, asked of every applicant: ability to meet the requirements of
tenancy, eligibility for housing or a priority reserved for people with
disabilities, current illegal drug use, and convictions for manufacturing
or distributing a controlled substance.

Nothing on that list is your chart. No diagnosis, no records, no symptom
list, no medication list, no dates of treatment. The letter's job is to
convey that a licensed clinician made the two findings, not to hand over
the reasoning that got them there.

## The city ordinance stops short of the accommodation

New Britain runs a Commission on Human Rights and Opportunities of its own,
which shares its name with the state agency and confuses people
accordingly. It is created at § 2-191 of the City's ordinances: seven
electors appointed by the mayor with common council approval, no more than
four from the same political party. The City lists it as meeting the third
Tuesday of the month at 6:00 pm in Room 201 of City Hall, 27 West Main
Street, with no meetings in July or August unless needed.

The ordinance behind it declares a city fair housing policy at § 2-198 and,
at § 2-199, makes it unlawful to deny housing to anyone, or to discriminate
"in the terms, conditions or privileges of sale, rental or leasing," on
grounds that include "mental or physical disability." Useful, but notice
what is missing. Nothing in the division mentions reasonable
accommodations in rules or policies, and nothing in it mentions animals.
The accommodation duty a New Britain tenant relies on is the state's.

Section 2-201 then says plainly what the city commission does with a
complaint: it "shall consider any and all complaints of violations of this
article and shall refer the same to the State of Connecticut Commission of
Human Rights and Opportunities and to the United States Department of
Housing and Urban Development." Its own duties list uses the same language,
process complaints and "make referrals to appropriate enforcement
agencies." That is a referral body, and knowing it in advance saves a month.

Enforcement of § 46a-64c belongs to the state commission. Complaints there
go in writing under oath, "except that a complaint that alleges a violation
of section 46a-64c need not be notarized," and § 46a-64c(a)(9) makes it a
discriminatory housing practice to coerce, intimidate, threaten or
interfere with anyone for exercising a right the section protects, which
includes having asked.

## The signature the whole thing turns on

Strip the request back and one thing in it cannot be supplied by the
tenant: a qualified person's judgement that the disability is there and
that the animal answers it. Since 1 July 2024 Connecticut's own statute
book has taken that as read. § 46a-64d tells the state commission to
publish materials on "permissible methods under state and federal law" for
a landlord to sort service animals from emotional support animals from
therapy animals, because the legislature treated the verification question
as one existing law already answers.

Have a therapist already? Ask them first; nothing else is close on cost. The
trade is a wait for the slot and a clinician who may be meeting the request
for the first time. A community mental-health clinic is the second option,
longer still, its intake written to open treatment rather than to close with
a letter.

A licensed evaluation is what reaches a letter when neither of those does:
screening questions, a Connecticut-licensed clinician, and a letter only
where the assessment supports one. No registry, tag or downloadable
certificate has ever performed that part of the request, and it is the only
part a New Britain landlord is entitled to see the conclusion of.

## What New Britain landlords can and cannot do

**Cannot:**
- Cannot refuse a reasonable accommodation in rules, policies, practices or services where it may be necessary to give a person with a disability an equal opportunity to use and enjoy a dwelling: Conn. Gen. Stat. § 46a-64c(a)(6)(C)(ii), and 24 C.F.R. § 100.204(a) federally.
- Cannot treat a no-pets policy as the end of the conversation, because a no-pets policy is one of the "rules, policies, practices or services" the statute names.
- Cannot apply a narrower idea of disability than Connecticut's own. Section 46a-64b(8) defines physical or mental disability as including, "but not limited to," the federal Fair Housing Act's "handicap": the federal test is the floor here, not the ceiling.
- Cannot demand a state registration, certificate or town tag for an emotional support animal. The free tag § 22-345 provides is for service animals as defined in 28 C.F.R. § 35.104, and no Connecticut tag exists for an ESA.
- Cannot charge pet rent, a pet deposit or a pet fee for an approved assistance animal, because the accommodation changes a rule rather than granting permission to keep a pet.
- Cannot demand a security deposit above two months' rent, or above one month's rent from a tenant aged 62 or older, § 47a-21(b), and must return it, or a written statement of damages, within twenty-one days.
- Cannot coerce, intimidate, threaten or interfere with a tenant for making the request or for helping someone else make one: § 46a-64c(a)(9).
- Cannot rely on the owner-occupied exemption in a three-family house. Section 46a-64c(b)(1)(B) reaches dwellings for "no more than two families" where the owner lives in the other unit, and stops there.

**Can:**
- May ask whether the tenant has a disability and a disability-related need for the animal, and may seek documentation establishing those two things: the boundary state and federal law draw, and the boundary § 46a-64d directs the commission to explain.
- May decline where the specific animal would be a direct threat or would cause substantial physical damage, on an individual assessment of the actual animal rather than a rule about its breed or weight.
- May count a refundable pet deposit against the § 47a-21(b) ceiling rather than on top of it, because the cap applies to any advance rental payment other than first month's rent or a key deposit.
- May fall outside § 46a-64c where the rental is a room in the owner's own single-family home, § 46a-64c(b)(1)(A). The federal Fair Housing Act still applies on its own terms.

## How to get an ESA letter in New Britain

1. **Check that you qualify**, Answer a short screening about how your condition affects daily life in New Britain. No diagnosis paperwork needed up front. (About 5 minutes: free)
2. **Connect with a licensed professional**, You are matched with a provider licensed for Connecticut clients who reviews your situation in a telehealth evaluation. (Telehealth evaluation)
3. **Complete your evaluation**, The professional evaluates whether an emotional support animal alleviates symptoms of a condition recognized in the DSM-5. Honest evaluations, not everyone qualifies. (Most of Our Applicants Qualify)
4. **Receive your signed letter**, Your letter arrives on the professional's letterhead with their license number: the documentation Connecticut landlords may lawfully request. (Typically within days of approval)
5. **Send it to your landlord**, Submit the letter with a short reasonable-accommodation request. Pet fees, pet deposits, and breed limits no longer apply to your animal in New Britain. (Protection under FHA + state law)

## Conditions that can qualify for an ESA

No fixed government list exists. A licensed professional evaluates whether an animal alleviates symptoms of a DSM-5-recognized condition, commonly:

- Generalized anxiety disorder
- Major depressive disorder
- Post-traumatic stress disorder (PTSD)
- Panic disorder
- Social anxiety disorder
- Obsessive-compulsive disorder (OCD)
- Bipolar disorder
- Attention-deficit/hyperactivity disorder (ADHD)
- Phobias with housing impact
- Chronic stress affecting daily function

## Housing help in New Britain

- [City of New Britain Human Rights & Opportunities Commission](https://www.newbritainct.gov/gov/boards/human-rights-opportunities-commission) (city agency)
- [Connecticut Commission on Human Rights and Opportunities](https://portal.ct.gov/chro) (state agency)
- [Connecticut Fair Housing Center](https://ctfairhousing.org/) (fair housing)
- [CTLawHelp](https://www.ctlawhelp.org/) (legal aid)

## Frequently asked questions

### What does my written request to a New Britain landlord actually have to say?

Two findings and one ask. The findings are that you have a disability within Conn. Gen. Stat. § 46a-64b(8), and that the animal is needed because of it. The connection is the whole point. The ask is the specific thing you want changed: name the rule. "I am asking for an exception to the no-pets clause in paragraph 14 of my lease" gives a leasing office something to answer; "I have an ESA" does not. Add the date, your unit, the name of the person you believe can decide, and a line asking for the answer in writing. Keep a copy of what you sent and how you sent it. None of that is a statutory requirement (the statute only speaks of the accommodation being necessary), but it is what turns a conversation into a record.

### Does "may be necessary" mean I have to prove the animal is essential?

No, and the drafting is deliberate. Section 46a-64c(a)(6)(C)(ii) defines discrimination to include "a refusal to make reasonable accommodations in rules, policies, practices or services, when such accommodations may be necessary to afford such person equal opportunity to use and enjoy a dwelling." Not "is necessary," not "is essential" — may be. The federal twin at 24 C.F.R. § 100.204(a) uses the same conditional. The comparison built into it is "equal opportunity": the question is whether, without the change, you get less use and enjoyment of the flat than a tenant without a disability would. A landlord who answers that you seem to be managing without one is answering a question the statute did not ask.

### My New Britain building has a 25-pound limit and a breed list. Does that end it?

No. Those are exactly the things the duty is pointed at. The statute names what has to give way: "rules, policies, practices or services." A weight cap is a rule. A breed list is a rule. A two-pet limit, a pet-rent line and a pet deposit are all rules. The duty attaches to the policy, not to the animal, which is why 24 C.F.R. § 100.204's own worked example of an accommodation is a reserved parking space rather than an animal at all. A landlord may still decline where this specific tenancy would be a direct threat to the health or safety of others or would cause substantial physical damage to the property of others: 24 C.F.R. § 100.202(d), but that is a finding about your animal, made on what it has actually done, not a category applied from a list.

### Is my landlord entitled to my diagnosis or my medical records?

No. Federal regulation makes it unlawful "to make an inquiry to determine whether an applicant for a dwelling … has a handicap or to make inquiry as to the nature or severity of a handicap of such a person", 24 C.F.R. § 100.202(c). The carve-outs that follow are ordinary screening questions asked of everyone: ability to meet the requirements of tenancy, eligibility for housing or a priority reserved for people with disabilities, current illegal drug use, and convictions for manufacturing or distributing a controlled substance. Nothing in that list is a request for your chart. So no diagnosis, no records, no symptom list and no medication list. What the letter conveys is that a licensed clinician reached the two findings, disability, and a disability-related need for this animal.

### Does New Britain's Human Rights & Opportunities Commission decide my complaint?

It receives it and passes it on. New Britain has a municipal commission of that name, created by ordinance at § 2-191 (seven electors appointed by the mayor with common council approval, no more than four from one party), and the City lists it as meeting the third Tuesday of the month at 6:00 pm in Room 201 of City Hall, 27 West Main Street, with no meetings in July or August. But § 2-201 sets out what it does with a housing complaint: the commission "shall consider any and all complaints of violations of this article and shall refer the same to the State of Connecticut Commission of Human Rights and Opportunities and to the United States Department of Housing and Urban Development." Its duties list says the same thing, process complaints and "make referrals to appropriate enforcement agencies."

### Once the accommodation is approved, can a New Britain landlord still charge pet money?

No, because the approval is not permission to keep a pet. It is a change to the rule that produced the charge. The pet deposit, the pet fee and the monthly pet rent are all rules within "rules, policies, practices or services," and an accommodation that leaves the fee schedule attached has not changed anything. Connecticut's ordinary deposit rules still run behind that: § 47a-21(b) caps the security deposit at two months' rent, or one month for a tenant aged 62 or older, and because § 47a-21(a)(11) counts an advance rental payment as a deposit unless it is "an advance payment for the first month's rent or a deposit for a key or any special equipment," the refundable pet deposit comes out of that ceiling rather than adding to it. You remain liable for damage the animal actually causes.

### Do I have to register the animal with the New Britain town clerk first?

No, and no Connecticut clerk can give you what the seller of a registration is describing. Dogs are licensed at the town clerk's office as dogs, whatever their role. The one animal-specific tag in the statute book is § 22-345, which gives a person with a disability whose dog is trained, or in training, as a service animal a licence and tag with "no fee" required, and defines "service animal" by 28 C.F.R. § 35.104, the ADA regulation that turns on individual training to do work or perform tasks. Animals whose function is emotional support fall outside it. So there is a free Connecticut tag and an emotional support animal cannot hold one, and there is no state ESA registry, certificate or card a New Britain landlord could ask you to produce.

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Get evaluated by a licensed provider: https://my.supportanimal.com/qualify?sa_source=blog&sa_medium=blog&sa_campaign=esa-guides&sa_content=markdown&ref=blog&sa_term=connecticut-emotional-support-animal%2Fnew-britain