As drafted, the current document does not take into account general cost of living for a voucher holder.  It says that to qualify for a unit only the portion the person would be paying must be considered. However, the purpose of having guidelines established at the property for screening applicants is to ensure they can afford to live and pay rent.  Simply calculating if a applicant can afford the unit based on only what they have to pay ignores normal living expenses everyone else would have to pay.

For example, the example used  - $1000 rent and $800 income along with $760 voucher and 3x the rent to qualify illustrates the following:

Person A- Non voucher- Income of $2000, would not qualify because $2000 is not 3x the rent.

Person B- non Voucher - income of $3000, would qualify as they are 3x the rent.

Person C- Voucher holder. Based on the information provided, to qualify the same way, you would say their income is $800+$760 voucher coverages= $1560. Which would still not enough to qualify.

Under the guidance as issued, we would be qualifying the person based on the rent they owe, not their total income, which would be treating them differently than everyone else.

It would work like this income=$1560, however instead of needing $3000 to qualify, the applicant would need only $720 ($240x3) $2,280 less than a non voucher holder.  That is inherently holding them to a different standard, and reverse discriminating against anyone who is not a voucher holder.

$1560 does not equal $3000 

We are being asked to calculate rent differently, not to ignore the SOURCE of funds.  The aim of this law as I understand it is so that someone who does get rental assistance is not treated differently, which would mean that the $1560 would be the income used to qualify, as we are not treating the $760 from the vouchers any different than funds from any other source.

Person B has $2000 to cover living expenses if you take rent into account. 

Person C (voucher) has only $560 to cover living expenses.

This is clearly not treating Person B & C the same based on source of funds, but treated differently by other means.