# ESA Letter in Dundalk, MD: The County Wrote the No-Fee Line Down

> Baltimore County's own housing department says a provider may not charge a fee for an emotional assistance animal. What that line does for a Dundalk renter.

- Source: https://supportanimal.com/blog/maryland-emotional-support-animal/dundalk/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-10
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 65,969
- Households renting: 35.4%
- Typical pet deposit (as a pet): Capped: 1 month's 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)

## Your county says it out loud

There is a fact sheet titled *Fair Housing Law*, last revised on 30 March 2023,
issued by the county housing agency, Baltimore County DHCD. Page 3 sets out
things a housing provider may not do to you. One of them is this:

> Charge a fee for a service animal or an emotional assistance animal

Read that again. Maryland's own fair housing statute uses the words "emotional
support" exactly once in the whole of Title 20, to push a comfort animal *out*
of the service dog definition. Yet Dundalk's own county housing agency sets an
emotional assistance animal alongside a service animal and puts both on the
no-fee side of the line.

Print that page. It is your landlord's county talking, not a website selling you
something.

## Which law is holding that sentence up

This part decides whether the line survives an argument, so be precise about it.

The fact sheet does not float the no-fee rule on its own authority. It files it
under a heading: **"Under the federal Fair Housing Act (FHA)."** The rule behind
it is therefore 24 C.F.R. § 100.204, the federal accommodation regulation, which
obliges a housing provider to adjust rules, policies, practices or services where
that is needed for a disabled resident to enjoy their home on equal terms.

Maryland carries a duty in the same shape at State Government § 20-706(b)(4).
Neither mentions animals, training or dogs. Both regulate **rules**, and a
no-pets clause, a pet-fee schedule and a monthly pet charge are all rules. Take
the rule away as an accommodation and the fee attached to it goes with it. That
is how the county's sentence works.

## Two Maryland sections that sound perfect and are not

Somebody will send you one of these. Both are real law. Neither is yours.

**State Government § 20-706(d)** promises a handler freedom from a lease's dog
ban and freedom from "any additional rent or fee." Perfect words, wrong door. The
definition sitting above it, at § 20-706(a)(3)(ii), carves out any dog that
"provides only emotional support, well-being, comfort, or companionship." That
carve-out was not an oversight; the General Assembly wrote it in with the rest of
the scheme, effective 1 October 2023.

**Human Services § 7-704(c)** goes further on its face. It speaks of housing
accommodations by name, promises access on equal terms, and forbids charging
extra compensation. Then § 7-701(g) narrows "service animal" to one individually
trained for work or tasks, and the door closes again.

The county fact sheet does not rely on either, and neither should you.

## Nobody in this county has a city hall

Dundalk is a census-designated place. No mayor, no council, no municipal code,
and this is the unusual part, **Baltimore County contains no incorporated towns
or cities at all**, anywhere within its borders. Not one. The Maryland State
Archives records the county as having no municipalities, which leaves the county
government as the only local government there is here. So "check with the town"
is not advice a Dundalk renter can act on. The county is the town.

One warning that costs people real time: Baltimore **County** and Baltimore
**city** are two separate governments with two separate commissions and two
separate deadlines. Dundalk is in the county. A complaint sent to the city office
about a Dundalk apartment is not a filing.

## What the county commission can actually do

The Baltimore County Human Relations Commission is staffed by the Division of
Diversity, Equity and Inclusion, at 308 Allegheny Avenue in Towson, on
410-887-5917. Its authority is County Code Article 29. Housing prohibitions live
at § 29-2-102, and the definition of "discrimination" at § 29-1-101(d) covers
disability of body and of mind in a housing case.

Do not mistake it for a comment box. Sections 29-3-101, -109 and -111 give
it hearings, orders, referral to circuit court and civil penalties. Under §
29-3-105(a) the Executive Director can also send a housing complaint on to
the state commission or the EEOC.

Two limits are worth knowing. Nothing outside Baltimore County is within its
remit, and § 29-1-101(h)(2) places three respondents beyond it as well: the
county itself, the school board and the community colleges. All 31 sections of
Article 29 were read for this page. There is no accommodation duty in the
article, and no animal of any kind is mentioned in it. Your ESA rule arrives from
Annapolis and Washington; the county supplies the forum, and the fact sheet
supplies the plain-English version.

## Six months on paper, 180 days on the web page

Here the county says two things and you should know both.

County Code § 29-3-103(b) gives you "not more than 6 months", measured either
from when the violation happened or from when you discovered it, whichever came
later for you. The county's own online complaint page instead puts the window at
180 days, then softens it, urging a late complainant to file anyway "as there may
be exceptions."

Six months and 180 days are not identical, and an invitation to file late is not
a promise to accept. Neither version tells you the comparison that matters:
against the State's year, both are short. Work to the shorter number and every
door stays open.

## The State's clock, and why filing locally does not spend it

Statewide, a housing complaint has **one year** to reach the Maryland Commission
on Civil Rights, under § 20-1021(a)(2). Its number is 410-767-8600 and a
Preliminary Questionnaire opens the file.

Pair that with COMAR 14.03.04.10D(3), under which a filing made at a local
commission during that year is treated as timely by the State as well. The county
route is a front door, not a diversion. Where the practice continued, the same
regulation starts the year at its **last** occurrence.

Three later numbers matter. Probable cause is targeted at **100 days**
(§ 20-1022(a)(2)). Once a charge issues, **20 days** is all either side gets to
demand court rather than an administrative hearing (§ 20-1026(b)). And § 20-1035
keeps a State court suit open for **two years**, available once 130 days have
passed, with punitive as well as actual damages on the table.

## Money, at the door and after

Maryland regulates what a landlord may collect up front, which matters if you are
quoted pet money anyway.

Real Property § 8-203(b)(1) holds the whole deposit to one month's rent per
dwelling unit, "regardless of the number of tenants." The trick is in
§ 8-203(a)(3), which identifies a security deposit by the job the money is doing,
protecting the landlord against unpaid rent or damage, no matter what heading
the lease files it under. A *refundable pet deposit* does exactly that job, which
puts it under the one-month ceiling instead of beside it. Section 8-208(d)(11)
then caps what can be demanded to start a tenancy at that deposit plus the first
month.

Both come with remedies. Collect above the cap and the tenant can claim treble
the excess with fees; merely handing over a lease containing a banned clause
triggers actual damages and fees under § 8-208(g). The policy itself has to reach
you before you apply, too: § 8-210(c) makes every landlord link it on the
property website and include it with the rental application, breed and weight
limits, pet numbers and every charge spelled out.

## One in three homes here is rented

Of the 25,154 occupied homes in Dundalk, 8,911 are rented. That is 35.4%, a
little above Maryland's 32.4%. Both figures, and the population of 65,969, come
from the American Community Survey's 2020–2024 five-year release. Nearly nine
thousand renting households, and not one municipal office among them.

## Nothing to register, and nothing to buy

No Maryland or Baltimore County agency registers an emotional support animal, and
neither issues a certificate, tag or ID card. Maryland has no misrepresentation
offence either.

Both § 20-706(b)(4) and 24 C.F.R. § 100.204 ask clinical questions: is there a
disability, and does this animal make equal enjoyment of the home possible. Those
are answered by someone qualified to answer them, in a letter written recently
about you. Nothing sold as a certificate speaks to either question.

## Where to start

Write to your landlord before you write to anyone else. Say that you are
requesting a reasonable accommodation, that a disability is the reason, that the
animal is what meets the need, and attach the documentation. Then add the
county's own fact sheet line. A landlord who shrugs at the FHA may still pause at
their own county's housing department.

If that fails, Baltimore County DHCD answers fair housing questions on
410-887-8383, and the Human Relations Commission takes complaints on 410-887-5917.
Maryland Legal Aid's Baltimore County office at 215 Washington Avenue, Suite 305
in Towson, on (410) 427-1800, lists ZIP 21222, Dundalk, among the areas it
serves. The Maryland Commission on Civil Rights is on 410-767-8600.

## What Dundalk landlords can and cannot do

**Cannot:**
- Cannot refuse to make a reasonable accommodation in a rule, policy, practice or service where it may be necessary for a tenant with a disability to have equal opportunity to use and enjoy the dwelling: Md. Code, State Gov't § 20-706(b)(4). A no-pets policy is a rule.
- Cannot rely on § 20-706(d)'s "no additional rent or fee" language to decide an emotional support animal request, in either direction: that subsection is written for a "service dog" as defined in § 20-706(a)(3), which expressly excludes an animal providing only emotional support.
- Cannot treat the owner-occupied exemption as covering a disability complaint: § 20-704(a)(2) is limited to sex, sexual orientation, gender identity, marital status, military status and voucher income, and disability is not among them.
- Cannot impose a security deposit greater than one month's rent per dwelling unit regardless of how many tenants sign, outside the narrow utility-assistance case, Md. Code, Real Prop. § 8-203(b)(1). Exceeding it exposes the landlord to three times the excess plus fees.
- Cannot use a lease requiring a tenant to pay more than that deposit plus the first month's rent to commence the lease and take occupancy, Md. Code, Real Prop. § 8-208(d)(11).
- Cannot enforce a lease provision prohibited by § 8-208, and owes actual damages plus reasonable attorney's fees for tendering one or making known an intent to enforce it, Md. Code, Real Prop. § 8-208(g).
- Cannot advertise or offer a rental in terms indicating a preference or limitation based on disability, Md. Code, State Gov't § 20-705(3).
- Cannot keep any part of a security deposit for damages if it failed to honour a tenant's certified-mail request to be present at the move-out inspection, Md. Code, Real Prop. § 8-203(f)(1)(vii).
- Cannot hold a security deposit past 45 days after the end of the tenancy without a reasonable basis, and owes interest at the one-year Treasury yield curve rate or 1.5%, whichever is greater, Md. Code, Real Prop. § 8-203(e).
- Cannot omit the pet policy from the rental application or the property website, and the policy must itemise breed and weight limits, pet limits, vaccination and insurance requirements, and every up-front fee, deposit and monthly charge: Md. Code, Real Prop. § 8-210(c).
- Cannot write a lease clause having the tenant waive or forgo any right or remedy provided by law, or waive a jury trial, Md. Code, Real Prop. § 8-208(d)(2), (d)(4).
- Cannot charge a late fee above 5% of the rent unpaid for the period in question, Md. Code, Real Prop. § 8-208(d)(3).
- In Montgomery County only, and only where more than three units are offered on one parcel or at one location, cannot prohibit a tenant aged 60 or older from keeping a household pet unless the prohibition was in writing at the time occupancy took place: Md. Code, Real Prop. § 8-214.
- Cannot keep a fee over $25 taken from a prospective tenant that is not a security deposit, beyond what was actually spent on the credit check or other application expenses, and owes twice the amount in damages if it does: Md. Code, Real Prop. § 8-213(b). Landlords with four or fewer units on one parcel, and seasonal and condominium rentals, are outside this section.

**Can:**
- May still refuse where the tenancy would be a direct threat to the health or safety of others or would result in substantial physical damage to the property of others, Md. Code, State Gov't § 20-703(5), but that turns on the tenancy, not on the species or the label.
- May hold the tenant liable for damage the animal actually does; an accommodation removes the charge for having the animal, not the cost of repairing what it breaks.

## How to get an ESA letter in Dundalk

1. **Check that you qualify**, Answer a short screening about how your condition affects daily life in Dundalk. No diagnosis paperwork needed up front. (About 5 minutes: free)
2. **Connect with a licensed professional**, You are matched with a provider licensed for Maryland 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 Maryland 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 Dundalk. (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 Dundalk

- [Baltimore County Human Relations Commission](https://www.baltimorecountymd.gov/boards-commissions/human-relations-commission) (county agency)
- [Baltimore County DHCD, Fair Housing Law](https://www.baltimorecountymd.gov/departments/housing/fair-housing/law) (county agency)
- [Maryland Legal Aid, office directory](https://www.mdlab.org/contact-us/) (legal aid)
- [Maryland Commission on Civil Rights, Housing](https://mccr.maryland.gov/know-your-rights/housing) (state agency)

## Frequently asked questions

### Has Baltimore County actually said in writing that my ESA cannot be charged a fee?

Yes. The Baltimore County Department of Housing and Community Development publishes a Fair Housing Law fact sheet, revised 30 March 2023, and page 3 lists among the things a housing provider may not do: "Charge a fee for a service animal or an emotional assistance animal." That is your landlord's own county government, in a document you can print and attach to a request. It is worth reading the heading it sits under too, because that tells you which law is doing the work.

### Which law is that no-fee line resting on?

The federal one. The fact sheet places that bullet expressly under "Under the federal Fair Housing Act (FHA)," so the authority is the federal reasonable accommodation duty at 24 C.F.R. § 100.204: a housing provider must make reasonable accommodations in rules, policies, practices or services when necessary for a person with a disability to have equal opportunity to use and enjoy a dwelling. Maryland carries a duty in the same shape at State Government § 20-706(b)(4). Neither provision mentions animals; both regulate rules, and a pet fee is attached to a rule.

### Can I use Maryland's rule that says no additional rent or fee for an animal?

No, and it is important not to lead with it. Section 20-706(d) of the State Government Article does say a handler is exempt from a lease clause banning dogs and "may not be required to pay any additional rent or fee", but § 20-706(a)(3)(ii) defines a service dog to exclude a dog that "provides only emotional support, well-being, comfort, or companionship." Human Services § 7-704(c) has the same problem, because § 7-701(g) requires an individually trained animal. Ask under the accommodation duty instead and you reach the same result on money.

### Dundalk has no city hall, so who handles a housing complaint here?

Baltimore County, and only Baltimore County. Dundalk is an unincorporated census-designated place with no mayor, no council and no municipal code, and the county contains no incorporated towns or cities at all: a genuinely unusual arrangement in Maryland. The local forum is the Baltimore County Human Relations Commission, staffed by the Division of Diversity, Equity and Inclusion at 308 Allegheny Avenue in Towson, on 410-887-5917. Fair housing questions go to county DHCD on 410-887-8383.

### Is the Baltimore County commission just advisory, or can it do something?

It has teeth. Its authority is County Code Article 29: housing prohibitions at § 29-2-102, and "discrimination" at § 29-1-101(d) covering physical and mental disability in housing. Sections 29-3-101, -109 and -111 give it hearings, orders, referral to circuit court and civil penalties. Under § 29-3-105(a) its Executive Director may also refer a housing complaint on to the state commission or the EEOC. What it cannot reach is county government itself, the Board of Education or the community colleges (§ 29-1-101(h)(2)).

### How long do I have to complain in Baltimore County, six months or 180 days?

The county states both, so treat the shorter as your working number. County Code § 29-3-103(b) says a person "shall file a complaint not more than 6 months after the alleged violation has occurred or has been discovered by the complainant." The county's online complaint page instead says within 180 days and adds that if the incident was longer ago, "please still submit your form, as there may be exceptions." Either way it is far short of the one year the state allows under § 20-1021(a)(2), so do not let the state clock lull you past the county one.

### Does the county code itself say anything about assistance animals?

No. All 31 sections of Baltimore County Code Article 29 were read for this page: there is no reasonable accommodation duty in it and no mention of an animal of any kind. That is not a gap in your rights: the duty arrives from the federal Fair Housing Act and from Maryland's § 20-706(b)(4), and Md. Code, State Gov't § 20-703(4) preserves local ordinances alongside them. Article 29 supplies the forum; the county DHCD fact sheet supplies the plain-English statement of what the rule means for a fee.

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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=maryland-emotional-support-animal%2Fdundalk