# Allentown ESA Rules: What Makes a Letter Count

> Allentown is 56.8% renters in Lehigh County. What Act 118 § 3(b) actually requires of ESA documentation, and the fair housing office that covers the region.

- Source: https://supportanimal.com/blog/pennsylvania-emotional-support-animal/allentown/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-07-29
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 127,138
- Households renting: 56.8%
- Typical pet deposit (as a pet): $0 for a documented assistance animal; ordinary deposits capped at two months' rent in year one, one month thereafter
- Typical pet rent (as a pet): $0 for a documented assistance animal; monthly pet charges are pet terms rather than accommodation terms
- Breed/weight limits common: yes
- Pet fees, deposits, and breed limits with a valid ESA letter: none (FHA reasonable accommodation)

## A Renter City in the Lehigh Valley

Allentown counted about 127,138 residents in the 2024 Census Bureau estimate,
and 56.8% of its households rent — nearly double Pennsylvania's 30.7%
statewide share, across roughly 26,000 renter households.

Most local disputes are not about whether an assistance animal is allowed.
Landlords here generally accept the principle. They get stuck on the letter:
whether it is on the right form, whether it came from the right kind of
professional, whether it is recent enough.

Pennsylvania answers all three questions in a single subsection, and none of
the answers are the ones landlords assume.

## The Three-Part Test

Section 3(b) of the Assistance and Service Animal Integrity Act — Act 118 of
2018 — requires supporting documentation to be in writing, to be reliable and
based on direct knowledge, and to describe the disability-related need for
the animal.

That is the whole standard.

**In writing.** A conversation is not documentation. This one favors the
landlord, and it is easy to satisfy.

**Reliable and based on direct knowledge.** This is the operative
requirement, and it is about the relationship rather than the paperwork.
Someone who has actually assessed the tenant and can speak to their situation
meets it. A service that issues letters after a web form does not, however
official the signature block looks.

**Describes the disability-related need.** The letter has to connect the
animal to the disability. It does not have to catalogue the condition.

Absent from that list: a mandatory form, a named profession, and any
expiry date. A landlord asking for a letter "dated within the last ninety
days" is asking for something § 3(b) does not describe.

## And Sometimes No Letter at All

Before any of that applies, § 3(a) has to be satisfied. A housing provider
may require documentation only if the disability or the disability-related
need is not readily apparent or known to the provider.

Where the need is already evident, the statute simply does not authorize the
request. It is worth asking, in writing, which element the provider considers
unclear — the answer either narrows the request or ends it.

## The Duty Being Administered

The obligation itself comes from § 5(h)(3.2) of the Pennsylvania Human
Relations Act. Under it, refusing an accommodation in rules, policies,
practices or services is unlawful wherever that accommodation may be needed
for a person to have equal opportunity to use and enjoy a housing
accommodation.

Act 118 then supplies the definition that closes the argument: an assistance
animal is an animal, other than a service animal, that qualifies as a
reasonable accommodation, and the term expressly reaches an emotional support
animal on that basis.

## What a Landlord Should Do With Doubts

Allentown landlords occasionally suspect a letter is manufactured, and
respond by inventing verification steps — demanding a phone call with the
writer, a notarized signature, a second opinion.

Act 118 provides a different route. Section 5 makes intentionally
misrepresenting entitlement to an assistance or service animal, or making
materially false statements for the purpose of obtaining documentation, a
misdemeanor of the third degree. That is a matter for the authorities, not a
license for a housing provider to build its own approval process.

Section 6 covers the accessories. Falsifying a document is a summary offense,
and so is dressing an animal that does not qualify in the harness, collar,
vest or sign that marks out an assistance or service animal. Each carries a
fine of up to $1,000. Between the two, Pennsylvania has more deterrent on the
books than most states — which is precisely why a landlord does not need to
improvise.

## What May and May Not Be Charged

Pet rent, pet fees and pet deposits are terms written for pets, and an
assistance animal that qualifies as a reasonable accommodation is not one, so
none of them attaches.

The deposit itself is limited for every Allentown tenancy by the Landlord and
Tenant Act of 1951: two months' rent at most in the first year of a lease,
one month's rent at most in the second and later years. A written list of
damages and the balance are due within thirty days of the tenant vacating,
and a landlord who misses that is liable in assumpsit to double the amount by
which the deposit exceeds actual damages.

## Housing Is the Question, Not Public Access

Act 118 draws a line between the two categories it names. A service animal is
defined by reference to the Americans with Disabilities Act and the
Pennsylvania Human Relations Act; an assistance animal is one that qualifies
as a reasonable accommodation, and expressly includes an emotional support
animal on that basis.

The accommodation an Allentown tenant is asking for concerns the dwelling —
permission to keep the animal at home, free of pet charges. Whether an animal
may enter a shop or restaurant is a separate question governed by different
rules, and a landlord who raises it in response to a housing request has
changed the subject.

## After a Refusal

A refusal that is going to be challenged should be pinned down first. Ask, in
writing, which specific requirement the provider considers unmet: is the
disability or need said to be readily apparent, so that no documentation was
needed at all, or is the submitted documentation said to fall short of
§ 3(b)?

That question does useful work either way. A landlord who cannot identify the
gap often reconsiders, and one who can has produced the written explanation
that a complaint to the Human Relations Commission would otherwise have to
reconstruct.

## The Federal Route

Alongside state law, the federal Fair Housing Act requires reasonable
accommodations in rules, policies, practices or services where necessary for
a person with a disability to use and enjoy a dwelling, a duty implemented by
regulation at 24 C.F.R. § 100.204. It is a second track
worth asking about, particularly given how short Pennsylvania's own deadline
is.

## Where to Get Help in Lehigh County

The Housing Equality Center of Pennsylvania provides direct services in seven
counties — Bucks, Chester, Delaware, Lehigh, Montgomery, Northampton and
Philadelphia — offering counseling and enforcement support to people who have
experienced housing discrimination and conducting fair housing testing. Lehigh
County's inclusion makes Allentown better served than most Pennsylvania cities
outside Philadelphia.

Disability Rights Pennsylvania is the statewide protection and advocacy
organization, and the Pennsylvania Legal Aid Network identifies the
appropriate legal aid provider for any county.

## Asking in a Later Year

Act 118 places no deadline on the tenant. A request raised in the fourth year
of a tenancy is judged on the documentation attached to it, not on the fact
that earlier years passed without one — circumstances and treatment change,
and the statute is concerned with the position now.

The only practical penalty for asking late is administrative: an animal
charge already written into a signed lease takes more correspondence to
remove than one that was never agreed.

## The Clock

Complaints go to the Pennsylvania Human Relations Commission, and § 9(h) of
the Human Relations Act sets the deadline at 180 days after the alleged act
of discrimination. Allentown has no city commission offering a longer window
the way Philadelphia does, so that six-month period is the whole runway.

Write the request down, note the date of any refusal, and do not let a
friendly negotiation consume the deadline. Our guide to
[what a landlord can and cannot do](/blog/articles/can-landlord-deny-emotional-support-animal/) explains how a denial is assessed, and
the [Pennsylvania ESA law overview](/blog/pennsylvania-emotional-support-animal/) covers the statewide rules.

## What Allentown landlords can and cannot do

**Cannot:**
- Cannot refuse to make reasonable accommodations in rules, policies, practices or services where the accommodation may be necessary for equal opportunity to use and enjoy a housing accommodation
- Cannot request documentation at all where the disability or the disability-related need is already readily apparent or known to the provider
- Cannot treat an emotional support animal as outside the rules, since Act 118 defines an assistance animal to include an ESA that qualifies as a reasonable accommodation
- Cannot require more than two months' rent as a security deposit in the first year of a lease, or more than one month's rent in later years
- Cannot keep any part of a deposit without providing a written list of damages and returning the balance within thirty days, on pain of liability for double the amount wrongfully withheld

**Can:**
- May require documentation where the disability or the need is not readily apparent, and may insist that it be in writing
- May insist that the documentation be reliable and based on direct knowledge and that it describe the disability-related need for the animal
- May report suspected misrepresentation, which Act 118 grades as a misdemeanor of the third degree for falsely claiming entitlement and as a summary offense carrying a fine of up to $1,000 for misrepresenting an animal

## How to get an ESA letter in Allentown

1. **Check that you qualify** — Answer a short screening about how your condition affects daily life in Allentown. No diagnosis paperwork needed up front. (About 5 minutes — free)
2. **Connect with a licensed professional** — You are matched with a provider licensed for Pennsylvania 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. (95% of applicants qualify)
4. **Receive your signed letter** — Your letter arrives on the professional's letterhead with their license number — the documentation Pennsylvania 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 Allentown. (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 Allentown

- [Housing Equality Center of Pennsylvania](https://equalhousing.org/) (tenant advocacy)
- [Pennsylvania Human Relations Commission](https://www.pa.gov/en/agencies/phrc.html) (government)
- [Pennsylvania Legal Aid Network](https://www.palegalaid.net/) (legal information)
- [Disability Rights Pennsylvania](https://www.disabilityrightspa.org/) (advocacy)

## Frequently asked questions

### What makes an ESA letter acceptable in Allentown?

Section 3(b) of Act 118 sets three requirements: the documentation must be in writing, it must be reliable and based on direct knowledge, and it must describe the disability-related need for the animal. Nothing in that list concerns a particular form, a specific profession, or how recently the letter was signed.

### Can my landlord insist on their own template?

The statute describes what the documentation must contain rather than what stationery it arrives on. A provider is entitled to information meeting the § 3(b) standard, and a submission that meets it is a valid request. Where the disability or need is readily apparent, § 3(a) means no documentation may be required at all.

### Which fair housing organization covers Lehigh County?

The Housing Equality Center of Pennsylvania provides direct services in Bucks, Chester, Delaware, Lehigh, Montgomery, Northampton and Philadelphia counties, including counseling and enforcement support for people who have experienced discrimination, and conducts fair housing testing.

### How long do I have to file in Allentown?

180 days from the alleged act of discrimination, under § 9(h) of the Pennsylvania Human Relations Act, filed with the Pennsylvania Human Relations Commission. Unlike Philadelphia, Allentown has no separate city commission offering a longer window, so the state deadline is the operative one.

### Does an emotional support animal count under Pennsylvania law?

Yes. Act 118 of 2018 defines an assistance animal as an animal other than a service animal that qualifies as a reasonable accommodation, and its coverage expressly includes an emotional support animal where the animal qualifies as a reasonable accommodation. The duty to accommodate sits in § 5(h)(3.2) of the Human Relations Act.

### Can a landlord charge more deposit because of the animal?

No. The deposit limits in the Landlord and Tenant Act of 1951 — two months' rent in the first year, one month afterward — apply to the tenancy, and an approved accommodation is not a pet arrangement that justifies adding to them. Damage the animal causes is a separate question settled at move-out.

### What happens if a landlord thinks the letter is fake?

Act 118 gives them a route that does not involve refusing outright. Section 5 makes intentionally misrepresenting entitlement, or making materially false statements to obtain documentation, a misdemeanor of the third degree. That is a criminal matter for the authorities rather than a basis for a housing provider to invent its own verification requirements.

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