Emotional Support Animal Letters in Philadelphia, PA

The One Pennsylvania City With a Longer Clock

Philadelphia counted about 1,573,916 residents in the 2024 Census Bureau estimate, and 48.2% of its households rent — well above Pennsylvania’s 30.7% statewide share, and roughly 328,000 renter households, the largest concentration of tenants in the state.

It is also the one place in Pennsylvania where a renter gets more time to complain than the state allows, which reverses the pattern most people expect from city-versus-state rules.

The Pennsylvania Human Relations Act sets the state deadline at § 9(h): a complaint must be filed within 180 days after the alleged act of discrimination. The Philadelphia Commission on Human Relations enforces the city’s Fair Practices Ordinance with a 300-day statute of limitations.

A Philadelphia tenant who let the state window close has not necessarily lost everything. That single fact is worth knowing before writing off a stale dispute.

Two City Bodies, One Right Answer

Philadelphia runs two housing-related commissions and they are easy to confuse.

The Philadelphia Commission on Human Relations handles discrimination complaints under the Fair Practices Ordinance. It sits at The Curtis Center, 601 Walnut St., Suite 300 South, and answers at (215) 686-4670. A refusal to accommodate an assistance animal belongs here.

The Philadelphia Fair Housing Commission is a separate city body dealing with unfair rental practices. It is a real forum for real problems, but it is not where an accommodation denial goes.

Filing in the wrong place burns weeks a 300-day clock can absorb and a 180-day clock cannot.

What Act 118 Actually Requires

Pennsylvania’s Assistance and Service Animal Integrity Act — Act 118 of 2018 — governs the paperwork side of the request statewide, including here.

An emotional support animal sits squarely inside the term the statute defines: an assistance animal is any animal, service animals aside, that qualifies as a reasonable accommodation, and the statute says so expressly. A Philadelphia landlord cannot treat an ESA as a category the rules miss.

Section 3(a) is the provision tenants most often need. Documentation of the disability and the disability-related need may be required only if that disability or need is not readily apparent to the provider, or otherwise known to it. Where the need is already evident, the statute does not authorize a demand for a letter.

Where documentation is properly sought, § 3(b) sets the standard: in writing, reliable and based on direct knowledge, and describing the disability-related need for the animal.

The Underlying Duty

Act 118 administers a duty it did not create. Section 5(h)(3.2) of the Pennsylvania Human Relations Act makes refusing reasonable accommodations in rules, policies, practices or services unlawful where those accommodations may be necessary for a person to have equal opportunity to use and enjoy a housing accommodation.

That is what a no-pets clause runs into, and what a breed restriction runs into. A rule that applies to pets is a rule, and the statute is about rules that have to bend.

Fees and Deposits in a Rowhouse Market

Philadelphia leases carry the usual animal pricing, and none of it attaches to an approved accommodation. An assistance animal is not a pet, so pet rent, pet fees and pet deposits do not follow it into the tenancy.

The deposit itself is capped for everyone by the Landlord and Tenant Act of 1951. Two months’ rent is the ceiling for a lease’s first year; from the second year onward the ceiling drops to a single month’s rent. Thirty days after the tenant moves out, two things fall due — an itemised written list of damages, and whatever escrow is left over. Miss that, and the statute makes the landlord liable in assumpsit for twice the sum by which the escrow exceeds the actual damages.

In a city where multi-year tenancies in the same rowhouse are common, the year-two reduction is the term most often ignored.

Skip the Vest

Pennsylvania is unusually direct about products sold as credentials. A fine of up to $1,000 is what § 6 of Act 118 attaches to a summary offense, and that offense is committed by falsifying a document, by making a false statement, or by putting a harness, collar, vest or sign of the sort assistance and service animals wear on an animal that does not qualify.

Section 5 covers the other half. A person who intentionally misrepresents an entitlement to an assistance or service animal, or who makes materially false statements in order to obtain documentation, commits a misdemeanor of the third degree.

Neither provision threatens a tenant who describes the animal accurately and submits a letter from someone who actually knows their situation. Both make the online accessories trade a bad idea in this state specifically.

Assembling the Request

A Philadelphia request that satisfies the statute is short.

Name the accommodation: permission to keep the animal in the unit, and exemption from any pet charge or restriction that would otherwise apply. Attach documentation meeting § 3(b) — written, from someone with direct knowledge, describing the disability-related need. Date it, and keep the reply.

Do not include a diagnosis narrative, a training record, or anything bought online. Section 3(a) limits the inquiry to what is not readily apparent, and § 3(b) describes a letter rather than a file.

Screening Comes First, Then the Request

Nothing obliges an applicant to raise an assistance animal while being screened for a Philadelphia apartment, and a disability is not a proper screening subject in the first place.

The order that avoids trouble is to apply on the ordinary criteria, then submit the accommodation request in writing once the application is approved and before the lease is executed. That keeps the animal out of a tenant-selection decision it should play no part in, and settles the fee question before an animal addendum has been signed.

A request made later is still valid — Act 118 imposes no timing rule on the tenant — but unwinding an executed term takes longer than declining one.

The Federal Layer Underneath

State law is not the only thing operating here. Where an accommodation in rules, policies, practices or services is necessary to give a person with a disability equal opportunity to use and enjoy a dwelling, the federal Fair Housing Act independently obliges the provider to make it — a duty the statute carries itself and HUD’s implementing regulation restates at 24 C.F.R. § 100.204.

For a Philadelphia tenant the practical consequence is that a complaint can run federally as well as through the city and state commissions — which matters most when a state deadline has passed and the facts are still fresh.

Where to Get Help

Community Legal Services is Philadelphia’s civil legal aid provider and handles housing matters for people who qualify. The Housing Equality Center of Pennsylvania serves Philadelphia among its seven direct-service counties, providing counseling and enforcement support for people who have faced discrimination.

For filing, the Philadelphia Commission on Human Relations is the city route with its 300-day window, and the Pennsylvania Human Relations Commission is the state route with 180 days.

Because the two clocks differ, the practical discipline is the same one that works everywhere else: put the request in writing, keep the answer, and write down the date of the refusal on the day it arrives. Our guide to what a landlord can and cannot do explains how a denial is judged, and the Pennsylvania ESA law overview sets out the statewide rules.