I submit the following comment on behalf of the Charlottesville Office of Human Rights, which upholds the Charlottesville Human Rights Ordinance, including protections against housing discrimination on the basis of source of funds. The Office of Human Rights supports the approval of the guidance document, as written.
I am specifically in support of the provision requiring minimum income calculations to be based on the voucher holder’s portion of the rent. If a landlord’s minimum income requirement calculations for voucher holders are based on the full market rent rather than the voucher holder’s portion of the rent, there is a possibility of systemic exclusion of voucher holders, especially when the landlord’s minimum income threshold is three times the full market rent.
For example, IF the voucher payment standard, utility allowance, and calculated tenant rent burden would qualify a voucher holder to rent a hypothetical unit at the full market rent:
BUT, if the minimum income requirement is based on a multiple of three times the market rent (rather than the voucher holder’s portion of the rent), resulting in an income requirement that is higher than HUD’s maximum income threshold permissible for voucher eligibility, THEN the voucher holder will be systematically excluded from renting the unit.
Calculating the minimum income requirement using the full market rent, rather that the tenant’s portion of the rent, especially when the minimum income requirement is three times the monthly rent, systematically excludes all voucher holders, discriminates against voucher holders on the basis of source of funds, and is therefore a violation of state law.