# ESA Letter in Keizer, OR: What "May Be Necessary" Actually Means

> Oregon's accommodation test is two words weaker than most landlords assume. Reading ORS 659A.145(2)(g) carefully is worth more than any document.

- Source: https://supportanimal.com/blog/oregon-emotional-support-animal/keizer/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-09-05
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 39,152
- Households renting: 37.1%
- Typical pet deposit (as a pet): Barred as accommodation
- Typical pet rent (as a pet): $25-$50/mo for pets
- Breed/weight limits common: sometimes
- Pet fees, deposits, and breed limits with a valid ESA letter: none (FHA reasonable accommodation)

## A suburb with its own numbers

Keizer rents 5,478 of its 14,782 occupied homes, 37.1 percent on the 2020–2024
American Community Survey five-year estimate, almost exactly Oregon's 36.7 percent
statewide figure. Median gross rent is $1,424, a little below the $1,525 state
level. The 2024 Census estimate puts the city at 39,152, fifteenth in Oregon.

Keizer sits directly against Salem's northern edge and shares its housing market
in every practical sense, while remaining a separate city. The numbers show the
usual suburban tilt: a renter share seven points below Salem's 44.1 percent, and a
median rent $24 **above** Salem's $1,400. Slightly more owner-occupied, slightly
more expensive.

The law is identical. ORS 659A.145 is a statewide provision, and so are ORS 90.300
and 90.302. What follows applies in Salem and everywhere else in Oregon just as it
does here.

## The test almost everybody gets wrong

When a Keizer landlord receives an accommodation request, they generally test it
against a standard they made up on the spot. Is the animal *essential*? Is it
*medically prescribed*? Could you not manage without it? What if you got a smaller
one?

None of those is the statutory question. ORS 659A.145(2)(g) makes it unlawful to
discriminate because of a disability by:

> "Refusing to make reasonable accommodations in rules, policies, practices or
> services when the accommodations **may be necessary** to afford the individual
> with a disability **equal opportunity** to use and enjoy a dwelling."

Two phrases in that sentence do all the work, and both are weaker than the
standard landlords tend to apply.

## "May be necessary", not "is necessary"

The legislature wrote a conditional. Not "when the accommodation is necessary."
Not "when the accommodation is required." **May be.**

That is a threshold that tolerates uncertainty. It does not ask a tenant, or a
clinician, to prove that the accommodation is definitively required: a thing that
is genuinely difficult to prove about any mental health accommodation, since the
counterfactual cannot be run. It asks whether it may be.

A landlord who says "you haven't shown you *need* the animal" has raised the bar
above the one the statute sets. That is worth saying, calmly, in writing, with the
words quoted.

## "Equal opportunity" — not survival

The second phrase sets what the necessity is measured against. The accommodation
may be necessary "to afford the individual with a disability **equal opportunity
to use and enjoy a dwelling**."

Equal to whom? To everyone else. The comparison is to a tenant without a
disability, living an ordinary tenancy in the same building.

This matters because the landlord's instinctive question, *could you cope
without it?*, measures against a floor. Could you survive, could you manage,
could you get by. The statute measures against a **standard**: the use and
enjoyment your neighbours have. A tenant who could technically manage without the
animal but would have a materially worse tenancy is inside the words the
legislature actually used.

And a related point about alternatives. The subsection does not say the
accommodation must be the only possible means. A landlord who proposes something
else (a ground-floor unit, a shorter term, a different building) is entitled to
raise it, and a request that engages honestly with a genuine alternative is
stronger for doing so. But "prove nothing else would work" is not the test either.

## What to put in the request

Given all that, the request itself can be short. Three things, in writing:

1. that you are a person with a disability;
2. that a clinician has determined this animal accommodates it;
3. that you are asking for an exception to the pet rule as a reasonable
   accommodation under ORS 659A.145(2)(g).

Reading the subsection carefully strengthens a request. It cannot make one true.
Oregon protects a person with a disability for whom an accommodation may be
necessary, and provides no roster of professions, no register and no official
form against which that could be checked. Only somebody qualified examining you
does that work.

Send it in a way you can prove, and date it. If no answer comes, send a short
follow-up saying that you will treat continued silence as a refusal after a stated
date. That converts an absence into something describable, and ORS 659A.820(2)
requires a complaint that sets forth "the acts **or omissions** alleged to be an
unlawful practice." The statute names omissions on purpose.

## If the request succeeds

The money follows the ordinary Oregon rules. ORS 90.300(4): a landlord "may not
charge a tenant a pet security deposit for keeping a service animal or companion
animal that a tenant with a disability requires as a reasonable accommodation
under fair housing laws." ORS 90.302(1) permits only the fees that section lists
and requires that any fee "must be described in a written rental agreement,"
which removes monthly pet rent for a required accommodation.

An ordinary security deposit remains lawful provided it is not larger because of
the animal, and damage the animal actually does remains yours.

One more thing that comes up in every Oregon city and is worth restating here
because it is the other standard landlords import from elsewhere: **training is not
part of the housing test.** ORS 659A.143(1)(a)'s "individually trained to do work
or perform tasks" definition opens with "As used in this section," and that
section governs places of public accommodation and access to state government
services. Housing is ORS 659A.145 and it defines no animal at all.

## The part no wording can substitute for

Reading the subsection carefully makes the request stronger. It cannot make it
true. ORS 659A.145(2)(g) protects an "individual with a disability"; ORS 90.300(4)
protects an animal the tenant "requires." Oregon names no clinicians, publishes no
list and recognises no registry, so the only thing standing behind those words is
whether somebody qualified assessed you.

Begin with whoever is already treating you. A counsellor, therapist or
prescriber holding years of your history speaks to a disability-related need
from a position no first appointment can reproduce, and the visit costs nothing
extra. The Salem–Keizer area's real friction is capacity (waits of several
months are normal), and a number of practices decline housing documentation as a
matter of policy.

Where it is not, a licensed evaluation arranges the same examination
deliberately. An Oregon-licensed clinician establishes whether a disability is
present and whether this animal accommodates it, then documents the conclusion
or explains that they cannot reach it. A guaranteed conclusion was reached
before you arrived.

Which brings the two halves together. Knowing that the statute says "may be
necessary" rather than "is essential" is what stops a landlord's invented standard
from ending the conversation. Having an actual determination is what makes there
be a conversation at all.

## What Keizer landlords can and cannot do

**Cannot:**
- May not refuse to make a reasonable accommodation in rules, policies, practices or services where it is necessary to give a disabled tenant equal opportunity to use and enjoy the dwelling: ORS 659A.145(2)(g). A no-pets policy is a rule, and the accommodation is an exception to it.
- May not charge a pet security deposit for a service animal or companion animal the tenant requires as a reasonable accommodation, ORS 90.300(4), which names the companion animal in the statute itself.
- May not charge any fee at the beginning of the tenancy for an anticipated expense, and may charge only the fees ORS 90.302 lists, each described in a written rental agreement.
- May not make a distinction or restriction against a renter in the price, terms, conditions or privileges of the tenancy because of disability: ORS 659A.145(2)(c).

**Can:**
- May still charge a noncompliance fee for failure to clean up a service or companion animal's waste from common areas, but only after a written warning notice, only for a second or later occurrence within a year, and capped at $50 under ORS 90.302(3).
- May still hold the tenant liable for damage the animal actually does, and may still take an ordinary security deposit, provided it is not larger because of the animal.
- Faces a disparate-impact claim under ORS 659A.425 where a facially neutral policy hits disabled tenants harder than tenants generally, weighed against the policy's business purpose and any less discriminatory alternative.

## How to get an ESA letter in Keizer

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

- [Salem Housing Authority](https://www.salemhousingor.com/) (housing authority)
- [Mid-Willamette Valley Community Action](https://www.mwvcaa.org/) (community action agency)
- [Fair Housing Council of Oregon](https://www.fhco.org/) (fair housing nonprofit)
- [Legal Aid Services of Oregon](https://lasoregon.org/) (legal aid)

## Frequently asked questions

### Does my animal have to be essential, or just helpful?

Oregon's words are "may be necessary to afford the individual with a disability equal opportunity to use and enjoy a dwelling." That is a lower threshold than "essential" in two ways. "May be" allows for uncertainty rather than requiring proof of necessity, and the necessity is measured against equal opportunity rather than against survival. A landlord asking whether you could cope without the animal is applying a standard ORS 659A.145(2)(g) does not contain.

### Do I have to prove nothing else would work?

The subsection does not say so. It asks whether the accommodation may be necessary for equal opportunity, not whether it is the only conceivable means to that end. Some landlords propose alternatives (a different unit, a shorter lease, a smaller animal), and a request that engages honestly with a genuine alternative is stronger, not weaker. But the burden the statute describes is not "exhaust every option first".

### What should the request actually say?

Three things, in writing: that you are a person with a disability; that a clinician has determined this animal accommodates it; and that you are asking for an exception to the pet rule under ORS 659A.145(2)(g). You do not need a diagnosis, a treatment history or a landlord-designed form. The statute requires none of those. Keep it short, dated and sent in a way you can prove.

### Can a Keizer landlord charge a pet deposit for my assistance animal?

No. ORS 90.300(4) provides that a landlord "may not charge a tenant a pet security deposit for keeping a service animal or companion animal that a tenant with a disability requires as a reasonable accommodation under fair housing laws." ORS 90.302(1) also permits only the fees that section lists and requires that any fee "must be described in a written rental agreement".

### Does my animal need training to qualify in Keizer?

No. The trained-animal test sits in ORS 659A.143(1)(a) behind the words "As used in this section," and that section is about public accommodations rather than homes. A tenancy falls under ORS 659A.145, which has no animal definition and no training standard in it.

### My landlord in Keizer also manages my parents' place in Salem. Does the same law apply?

Yes. ORS 659A.145 is a statewide provision and does not vary by city: Keizer, Salem and everywhere else in Oregon are governed by the same section, and ORS 90.300 and 90.302 apply to residential tenancies statewide. What varies between the two cities is the market rather than the law: Keizer's renter share is seven points below Salem's and its median rent slightly above.

### What if the landlord simply does not answer the request?

Silence functions as a refusal once enough time has passed, and the practical step is to send a short follow-up that says so and gives a date. That converts an absence into an act you can describe. ORS 659A.820(2) requires a complaint that sets forth "the acts or omissions alleged to be an unlawful practice" (the statute names omissions expressly), filed within one year of the practice.

---

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=oregon-emotional-support-animal%2Fkeizer