# ESA Letter in Auburn, WA: Owner Lettings, Records & Pet Charges

> Auburn rents at 39.4%, split between owner-let houses and managed complexes. Why the rules reach a two-property landlord, and what to get in writing.

- Source: https://supportanimal.com/blog/washington-emotional-support-animal/auburn/
- Publisher: Support Animal (supportanimal.com)
- Updated: 2026-08-02
- License note: informational content; not legal or medical advice.

## Key facts

- Population: 85,513
- Households renting: 39.4%
- Typical pet deposit (as a pet): Varies by building
- 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)

## Two kinds of landlord in one valley

Auburn rents at 39.4%: around 12,000 of 30,393 occupied units on the
2020-2024 American Community Survey five-year estimate. That is a noticeably
lower share than the neighbouring valley cities, with Kent at 42.8%, Federal
Way at 44.7% and Renton at 45.6%, though still above the statewide 36.2%.

The composition matters more than the number. Auburn's rental housing splits
fairly evenly between single-family houses let by the people who own them and
mid-sized apartment developments operated by management companies.

Those two landlords behave in opposite ways. The company decides by written
policy and documents every step. The owner decides across a kitchen table and
documents nothing. An assistance animal request runs into a different failure
mode in each.

## Scale does not change the obligation

Owners letting one or two properties frequently assume that rules of this kind
are aimed at somebody larger.

WAC 162-38-040 forecloses the argument in its definitions. For this chapter
the word covers whoever exercises control over a property on the strength of
owning it, anybody but the occupier, and the regulation then itemises the
category: owners letting property, trustees, receivers, and anyone acting as
their agent.

There is no threshold. An owner letting a single house on Lea Hill is a
landlord for these purposes, and WAC 162-38-100(3) applies to them exactly as
it applies to a hundred-unit complex: a no-pet policy cannot be applied to the
assistance animal of a person with a disability, and refusing to rent on that
basis is an unfair practice.

## The approval that exists only in memory

The characteristic Auburn problem is not refusal. It is an approval nobody
wrote down.

An owner who agrees to the animal has granted an accommodation, and nothing in
chapter 162-38 WAC requires that to be in writing to be effective. The
difficulty arrives eighteen months later, when the property is sold, or the
owner hands the keys to a relative or a letting agent, and a new person reads
an old no-pets clause.

The obligation itself survives the handover, because the definition above
reaches agents and others acting in the owner's interest. What does not
survive, absent a document, is the evidence.

A short email (sent the same day, restating what was agreed) is the cheapest
protection available in this market, and it is the single most useful thing a
tenant here can do.

## What the managed side charges

Apartment developments take the opposite approach, pricing animals in the
lease and applying it automatically.

WAC 162-38-100(5) does not permit an animal-specific deposit alongside the
standard cleaning or damage deposit where the tenant is disabled and the
animal assists with the disability. Where the charge is billed monthly instead
of at signing, it is the same demand on a different schedule.

Subsection (4) sets out what remains: the building may enforce its ordinary
cleaning or damage deposit on a tenant with an assistance animal, so long as
it enforces that deposit equally on all tenants. The comparison is against the
building's general practice, not against its pet policy.

Where ordinary deposits and fees are charged, RCW 59.18.610 gives a tenant who
asks in writing the right to pay them across three consecutive equal monthly
instalments on a term of three months or longer, with no fee or interest for
choosing that route.

## The inspection that has to happen first

This provision applies to both kinds of landlord and is skipped far more often
by the informal one.

Under RCW 59.18.260 a deposit may not be taken at all in the absence of two
documents: a written agreement, and a signed, dated record of how the place
looked at handover: paintwork, flooring, furniture and appliances included.
Both parties sign it, the tenant keeps a copy, and one free replacement can be
requested later.

Where a deposit is taken and no checklist produced, the sum falls due back to
the tenant, and the successful party can claim court costs and reasonable
attorneys' fees besides.

The relevance to animals is direct. When a scratch or a stain is attributed to
a dog at move-out, the absence of a move-in record leaves the landlord with
nothing to compare it against.

## Training is not the housing test

Both kinds of landlord reach for the state's service animal definition, and
both reach for the wrong one.

RCW 49.60.040(25) defines a service animal as an individually trained dog or
miniature horse and excludes emotional support, comfort and companionship from
the meaning of work or tasks. It then closes by disapplying the subsection to
RCW 49.60.222 through 49.60.227 in respect of housing accommodations and real
estate transactions.

That range is Washington's fair housing law in its entirety. The training
standard operates in employment and public accommodation. In a home, the
governing provision is RCW 49.60.222(2)(b) and its reasonable accommodation
duty.

## What a demand for removal requires

Insisting the animal leave is available under WAC 162-38-105 on proof of two
matters at once. One is hazard: the animal's conduct putting people or
property in unreasonable danger. The other is history: a prior, sensible
attempt at correcting that conduct which did not take.

The supporting rules are strict. Speculation is not enough; the danger has to
be present or plainly likely. Irritation, whether from the office or from
neighbours, is not danger. Whether the animal itself is at risk is for its
owner to weigh. And trouble in one corner of a property will not justify
shutting the animal out of the whole.

## Certificates, and the penalty that sits elsewhere

Owners letting a house for the first time tend to research the subject online,
where two claims circulate together: that a tenant should produce a
registration or certificate, and that misusing the label carries a penalty
that might reach a tenancy.

Neither is right. Washington keeps no register of assistance animals and no
agency here issues certificates, cards or vests, so a purchased document
addresses none of the questions WAC 162-38 puts, which are whether the person
is disabled and whether the animal is needed because of that.

The penalty half-remembered from those searches belongs to another setting
entirely. RCW 49.60.214 makes it a civil infraction to pass an animal off as a
service animal to obtain the access such animals are given, and
RCW 7.80.120(1)(a)(iii) fixes the maximum and the default at five hundred
dollars. It is enforced in shops and other public accommodations, by an
officer limited to two questions who may not ask for paperwork. It has no
application to a home.

## Where to take it

Housing discrimination complaints go to the Washington State Human Rights
Commission. Six months is the general ceiling in RCW 49.60.230(2); housing
sits outside it, and a matter under RCW 49.60.222 through 49.60.225 carries
twelve months from the point the practice happened or stopped. Submissions
go through the commission's online portal, and it staffs a toll-free line on
1-800-233-3247.

King County runs a Civil Rights Program of its own, covering housing among
other areas, at civilrights@kingcounty.gov or 206-263-2446.

Whichever kind of landlord is on the other side, get the decision in writing.
Against a management company that is a matter of asking for the file. Against
an individual owner it usually means writing the email yourself.

For the statutes behind these rules, see the
[Washington ESA law guide](/blog/washington-emotional-support-animal/), and our
[guide to getting an ESA letter](/blog/articles/how-to-get-esa-letter/) for what
a defensible letter contains.

## What Auburn landlords can and cannot do

**Cannot:**
- Cannot apply the trained-task definition of a service animal to a housing request, because RCW 49.60.040(25) states that the subsection does not apply to RCW 49.60.222 through 49.60.227 for housing accommodations or real estate transactions
- Cannot refuse to make reasonable accommodation in rules, policies, practices or services where that accommodation may be necessary to afford a person with a sensory, mental or physical disability equal opportunity to use and enjoy a dwelling
- Cannot apply a no-pet policy to the assistance animal of a person with a disability, under WAC 162-38-100(3)
- Cannot charge a pet deposit on top of any standard cleaning or damage deposit, which WAC 162-38-100(5) makes an unfair practice outright
- Cannot demand that the animal be removed unless its presence, behaviour or actions pose an unreasonable risk of injury or harm and a reasonable attempt to correct that behaviour has already failed, under WAC 162-38-105
- Cannot treat staff or neighbour annoyance at the animal as the kind of risk that justifies removal, and cannot exclude it from the whole property over a risk confined to part of it
- Cannot inquire into matters personal to a disabled applicant beyond what is necessary and appropriate to the landlord-tenant relationship, under WAC 162-38-110
- Cannot require a waiver of rights or a hold-harmless as a condition of the transaction because a disabled person or a person with an assistance animal will occupy the property, under WAC 162-38-120
- Cannot collect any deposit at all without a written agreement and a signed move-in checklist, or keep any of it without a documented statement within thirty days

**Can:**
- May charge its standard cleaning or damage deposit, provided the same deposit is enforced equally on every tenant, which WAC 162-38-100(4) expressly permits
- May ask for information supporting the disability and the disability-related need for the animal where neither is readily apparent
- May hold the tenant responsible for damage the animal actually causes, substantiated at move-out by invoices or estimates like any other charge
- May fall outside the accommodation duty entirely in two narrow cases under RCW 49.60.222(2): an unadvertised single-family house let by an owner holding no more than three, and an owner-occupied dwelling of no more than four units, though the section's other prohibitions still apply

## How to get an ESA letter in Auburn

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

- [King County Civil Rights Program](https://kingcounty.gov/en/dept/executive/governance-leadership/equity-social-justice/office-of-equity-racial-social-justice/civil-rights-program) (county agency)
- [Washington State Human Rights Commission](https://www.hum.wa.gov/fair-housing) (state agency)
- [Fair Housing Center of Washington](https://www.fhcwashington.org/) (fair housing)
- [Northwest Justice Project](https://nwjustice.org/get-legal-help) (legal aid)

## Frequently asked questions

### My landlord rents out two houses. Do the regulations apply to him?

They do, because the chapter is written around control of the property rather than the scale of the business. In WAC 162-38-040 the term covers whoever exercises control over the property on the strength of owning it, anyone but the occupier, and the list runs through owners letting property, trustees, receivers and anybody acting as their agent. Nothing in chapter 162-38 WAC scales with the number of units held.

### He agreed to the animal but nothing is in writing. Is that a risk?

The approval is valid; proving it later is the difficulty. Properties are sold, owners hand management to an agent, and a new party reads an old no-pets clause. The obligation travels with the property because WAC 162-38-040 covers agents and others acting in the owner's interest, but only a written record makes that easy to establish, so an email confirming the conversation on the day it happens is worth sending.

### Can I be charged a pet deposit for an assistance animal?

Not on top of the deposit everyone pays. WAC 162-38-100(5) does not allow an animal-specific deposit alongside the standard cleaning or damage deposit where the tenant is disabled and the animal assists with that disability. Subsection (4) leaves the ordinary deposit in place on one condition. That the landlord enforces it equally on all tenants rather than only where an animal is present.

### What if the deposit was taken with no move-in inspection?

That is the landlord's problem rather than yours. RCW 59.18.260 bars collecting any deposit unless the rental agreement is in writing and a checklist describing the condition and cleanliness of the premises is signed and dated by both parties at the start of the tenancy. Miss that step and the sum becomes owed straight back to the tenant, with the successful party able to claim court costs and reasonable attorneys' fees.

### Does the animal need training to qualify here?

No. The trained dog-or-miniature-horse test in RCW 49.60.040(25) excludes comfort and companionship from what counts as work or tasks, then removes itself from RCW 49.60.222 through 49.60.227 wherever housing accommodations or real estate transactions are involved. Those sections are Washington's fair housing law in full, so the training standard governs nothing in a tenancy.

### How much time do I have to complain about a refusal?

A year. RCW 49.60.230(2) applies a six-month limit to discrimination complaints as a class and then treats real estate separately, allowing twelve months for a matter under RCW 49.60.222 through 49.60.225 from the date the practice occurred or terminated. Complaints go to the Washington State Human Rights Commission; King County also operates a Civil Rights Program covering housing among other areas.

### How does Auburn compare with its neighbours on renting?

Auburn rents at 39.4%, roughly 12,000 of 30,393 occupied housing units, on the 2020-2024 American Community Survey five-year estimate. That is below Kent at 42.8%, Federal Way at 44.7% and Renton at 45.6%, though a little above the statewide figure of 36.2%.

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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=washington-emotional-support-animal%2Fauburn