It doesn't have to be 100% wheel chair accessible. 

A few years later one of my agents was in a horrific accident and when he finally got out of the hospital he was confined to a wheel chair and little movement.

If Landlord occupies the building and is severely allergic to the animal, it is not "reasonable" to allow the animal in the unit and risk his health.The same goes for wheelchairs.

Even though she got 60 days notice, she still couldn’t find an apartment in the area that was first floor and wheelchair accessible.

The owner is elderly, in a wheelchair and doesn’t want to be a landlord anymore.

@Kathy Hansen That's pretty hilarious, except for the fact that you were in a wheel chair.

So, as an alternative I let them choose to get the liability coverage for their animal that covers me.Its the same as someone with a wheelchair, if they want to have a ramp into your house, they have to pay for it and pay to remove it and restore the property when they leave. 

One guy dead in a bed.. so not to bad ,,  took him,, family rolled up mattress like burrito so easy clean up...One guy dead in wheelchair,, after about day & half  found by cable installer,.. 

Quote from @Patti Robertson: If the animals are truly ESAs you cannot deny them any more than you could deny a tenant in a wheelchair building a rent to enter the front door. 

All parts of the house are wheelchair accessible, including the walk-in style bathrooms.