Texas Comptroller of Public Accounts

Texas Comptroller of Public Accounts, Glenn Hegar

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Chapter 2
Focus on Appraisal Districts: Operations

Before the Legislature created appraisal districts in 1981, thousands of governmental taxing entities appraised property and assessed taxes independently, resulting in wide disparities in value. As property tax levies increased and the state began to base more aid to school districts on property values, centralized local appraisal became necessary to ensure equal taxpayer treatment.

The CAD system greatly improved equity in property taxation and school funding, although there are still wide differences in individual CAD practices. Each year, the Comptroller's Property Tax Assistance Division (PTAD) surveys the state's 253 CADs for information about their operations.[11] The CADs provide these historical data for the prior tax year and projected data based on budgets and plans for the current tax year.

The differences in responses reported in the PTAD's annual survey reflect the CADs' diversity. While the range in survey results makes generalized observations difficult, it does demonstrate the complexity of the CADs' daily operations, the massive job they perform each year and the benefit they provide to local taxing units.

The Comptroller's office provides CAD information to legislators, taxpayers, news media, local taxing entities, state agencies and CADs. PTAD uses the information to prepare legislative fiscal estimates and as background for its methods and appraisal practices (MAP) reviews. CADs use the information to compare their operations with those of other CADs.

The complete survey data are available on the Comptroller's Web site at www.window.state.tx.us/taxinfo/proptax/annual08/2008-09_operations_survey_raw_data.xls. Following are highlights of the information contained in the surveys.

CAD Governance

A board of directors selected by the taxing units within the county governs each CAD. The directors hire the chief appraiser, establish the CAD's goals and policies, appoint ARB members and approve agricultural advisory board members.[12]

Tax Code Section 6.03 requires that if a taxing unit does not appoint the county tax assessor-collector to the CAD board, the county assessor-collector serves as a non-voting CAD director. If a county tax assessor-collector serves as the CAD's chief appraiser, however, or if the county commissioners court contracts with another taxing unit to collect county taxes, the county tax assessor-collector is ineligible to serve on the CAD board.

Most board members are citizen appointees of the taxing units in the CAD, but 689, or about half of all directors, are taxing unit officials, including county tax assessor-collectors, school board members, county judges, county commissioners, city council members and other elected officials. They represent the interests of the respective taxing units that appoint and elect them. The number of taxing unit officials on CAD boards declined by 103, or 13 percent, from the total of 792 elected officials who served in 2007.

To protect against errors and omissions by board members, 194 CADs purchase liability insurance; 58 do not purchase this insurance protection. Two hundred three CADs reported that they retain legal counsel to advise the board on legal issues that may arise from CAD operations while 32 do not have legal counsel on retainer.[13] Thirty one law firms represent CADs, with five law firms representing 174 CADs, or 85.7 percent (Exhibit 7).

Exhibit 7
Top 5 Law Firms Representing CADs, 2008

Law Firm Number of CADs Represented
Perdue, Brandon, Fielder, Collins & Mott 82
Hargrove & Evans 31
McCreary, Veselka, Bragg, & Allen 23
Peter Low 21
Linebarger, Goggan, Blair & Sampson, LLP 17
Total 174
Percent of CADs with Attorney Representation 85.7%

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.

Agricultural Advisory Boards

Tax Code Section 6.12 requires the chief appraiser, with the advice and consent of the CAD's board, to appoint three or more members to an agricultural appraisal advisory board (Ag board). The Ag board advises the chief appraiser on the appraisal and use of land designated for agricultural, open space or timberland appraisal.

In 2008, 189 of the state's 253 CADs reported having Ag boards with a total of 787 members. The average Ag board has four members. Fifty CADs indicated they do not have an Ag board.

CAD Operations

CAD Budgets

Local taxing units pay CAD expenses according to their share of the total property tax levy of all the taxing units in the CAD. Tax Code Section 6.06 permits taxing units served by a CAD to veto the CAD's budget, but only three taxing units did so in 2008.

Final 2008 CAD operating expenses totaled $351 million, or a reported mean average of $27.81 per parcel appraised. The average 2008 CAD operating budget exceeded $1.4 million, 7.6 percent more than in 2007. CADs approved budgets for 2009 totaling $374.5 million, an increase of 6.7 percent.

The top 10 CADs account for 46.7 percent – or nearly half – of all CAD budgets in the state (Exhibit 8).

Exhibit 8
Top 10 CAD Proposed Budgets, 2009

CAD 2009 Adopted Budget
Harris County $63,389,143
Dallas County $21,380,063
Tarrant County $19,003,352
Bexar County $14,278,245
El Paso County $12,242,388
Travis County $11,856,540
Collin County $10,551,600
Denton County $9,563,783
Williamson County $6,493,537
Nueces County $6,038,419
Total Top 10 Budgets $174,797,070
Total CAD Budgets Statewide $374,539,001
Percent Top 10 Budget of Total Budgets 46.7%

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.

Grouping the CADs by account sizes shows the variance in costs per account (Exhibit 9).

Exhibit 9
2008 CAD Spending by Size

Number of Accounts Number of CADs[14] Average 2008 Expenses Average Cost Per Account
Below 5,000 4 $109,288 $17.66
5,000 to 9,999 26 $148,375 $19.84
10,000 to 14,999 24 $183,308 $16.09
15,000 to 19,999 23 $288,495 $16.19
20,000 to 24,999 16 $422,497 $19.12
25,000 to 34,999 33 $519,472 $27.28
35,000 to 49,999 34 $780,128 $17.13
50,000 to 74,999 26 $960,619 $16.24
75,000 to 149,999 26 $1,596,226 $15.78
150,000 to 300,000 15 $3,287,208 $18.39
More than 300,000 10 $15,948,371 $26.40

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.

CADs indicated they had accumulated $22.9 million in surplus funds, 27.8 percent less than in 2007. The decline was largely due to a decrease in the Harris CAD fund balance from $11.1 million to less than $1 million. Exhibit 10 lists the 10 CADs with the largest surpluses in 2008.

Exhibit 10
CADs with 10 Largest Surpluses, 2008

CAD 2007
Tarrant County Appraisal District $3,598,951 $3,085,794 ($513,157)
Fort Bend County Appraisal District $434,425 $2,033,356 $1,598,931
Jefferson County Appraisal District $1,933,116 $1,598,773 ($334,343)
Travis County Appraisal District $722,980 $1,444,652 $721,672
Webb County Appraisal District $700,000 $782,041 $82,041
El Paso County Appraisal District $726,501 $691,404 ($35,097)
Harris County Appraisal District $11,188,626 $647,725 ($10,540,901)
Brazos County Appraisal District $600,000 $600,000 $0
Hood County Appraisal District $497,000 $585,000 $88,000
Collin County Appraisal District $0 $581,952 $581,952

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.

Most CADs enter into contracts with third-party vendors to provide appraisal services for complex properties such as mineral reserves and utilities. In 2008, 226 CADs had these contracts at a cost of slightly more than $17 million, or an average of $75,421 per CAD.

Nearly all CADs (245) included a budget line item for staff training. Statewide training budgets totaled slightly less than $3 million, or an average of $12,046 per CAD.

CAD Staff

Chief appraisers oversee CAD staff and operations. Employment arrangements within the CADs vary with CAD size and workload. The largest CADs commonly have as many as 200 staff members, while a small CAD may employ only part-time appraisers or contract for appraisal work.

One hundred eighty-two CADs reported that the chief appraiser performs appraisals; 52 said that he or she did not; and 21 did not respond to this question. On average, chief appraisers earned $60,200 annually, ranging from a low of $6,600 in Hardeman CAD to a high of $171,385 in Harris CAD. Exhibit 11 lists the top 10 chief appraiser salaries.

Exhibit 11
Top 10 Chief Appraiser Salaries, 2008

CAD Chief Appraiser
Harris County Appraisal District $171,385
Dallas County Appraisal District $168,935
Bexar County Appraisal District $145,600
El Paso County Appraisal District $135,700
Tarrant County Appraisal District $135,000
Collin County Appraisal District $132,500
Smith County Appraisal District $132,000
Denton County Appraisal District $131,122
Williamson County Appraisal District $126,000
Jefferson County Appraisal District $122,294

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.

Fifty-one chief appraisers also received pay as tax assessor-collectors. Most CADs (237) provide the chief appraiser retirement benefits and 225 provide them medical insurance. Two hundred five CADs provide the chief appraiser with liability insurance coverage.

Full-time CAD employees numbered 4,392 in 2008, with 850 holding supervisory positions and another 315 involved in collection activities. The CADs employed 1,761 professional appraisers, representing 40.1 percent of all full-time CAD employees. Salaries for CAD appraisers in 2008 ranged from an average of $28,598 to $45,877. CADs employed 74 computer programmers, paying them average amounts ranging from $47,133 to $62,401.

Appraisers must be registered with the Board of Tax Professional Examiners (BTPE) and must either be a registered professional appraiser (RPA) or enroll in training to become one within five years of their employment as an appraiser.[15] Texas CADs reported that 2,196 of their employees have certifications issued by BTPE. Statewide, 1,296 appraisers have obtained the RPA designation; 249 are registered Texas assessor-collectors; 126 are registered Texas tax collectors; and 86 individuals have all three designations.

In 2008, some 215 CADs provided staff with medical insurance and 228 provided retirement benefits.

CAD Appraisal Work

In 2008, Texas CADs appraised more than 17 million pieces of property valued at more than $1.9 trillion, an increase from 2007, when appraised property totaled $1.7 trillion.

Exhibit 12 highlights the appraisal district workload for the 25-year period from 1984 through 2008.

A parcel is any item of real property, regardless of size, that has a single owner or multiple owners in undivided ownership and for which there is a separate appraisal record.

Exhibit 12
25-Year Review of Appraisal District Workload

Year Taxable
Appraisal Notices Sent ARB Hearings Scheduled
1984 12,206,774 4,629,682 151,144
1985 12,568,931 4,731,365 91,665
1986 12,803,055 4,428,225 125,246
1987 12,786,518 5,054,336 163,085
1988 12,937,341 3,977,007 170,711
1989 13,225,514 4,160,375 157,947
1990 13,139,219 7,191,615 178,124
1991 13,518,442 7,199,515 209,889
1992 13,320,845 7,465,478 196,503
1993 13,546,649 8,383,541 166,056
1994 13,723,699 7,810,313 218,538
1995 14,099,466 8,241,057 195,097
1996 14,304,085 7,654,301 189,769
1997 14,617,741 7,586,079 149,771
1998 14,847,469 8,160,120 189,622
1999 14,756,523 8,743,293 248,526
2000 15,022,588 8,420,244 234,691
2001 15,385,913 9,364,893 306,836
2002 15,618,958 9,068,428 379,325
2003 16,007,636 9,088,784 359,743
2004 16,470,682 9,161,839 421,542
2005 16,640,895 9,451,847 472,537
2006 16,744,311 9,600,405 505,951
2007 17,055,232 Not Reported 649,483
2008 16,956,870 Not Reported 723,423

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.


State law requires CADs to re-appraise property in their jurisdiction at least once every three years. Many re-appraise property every year. For the 2008 tax year, CADs re-appraised 61.5 percent of parcels not appraised by contractors. CADs re-appraised 61.2 percent of such parcels in 2007 and plan to re-appraise 67 percent in 2009. The CADs also plan to re-appraise 92.2 percent of contracted parcels in 2009, and re-appraised 91.1 and 90.6 percent in 2007 and 2008, respectively. This data reflects the mean average of the data reported by the CADs.

One hundred eighty-one CADs conducted ratio studies in 2008, while 20 did not. Fifty-two CADs did not provide information on this subject.


Tax Code Section 11.14 entitles a property owner to an exemption from taxation of tangible personal property that the owner does not use to produce income. Manufactured homes do not qualify for this exemption. A taxing unit may opt to tax property exempted by Section 11.14, however, and 433 Texas taxing units have chosen to do so. Sixty-seven cities tax leased vehicles used primarily for personal purposes.

Tax Code Section 11.261 allows a county, city or junior college district to limit taxes (also called a tax ceiling) for homeowners who are either disabled or 65 or older or both. One hundred fifty-three CADs reported that taxing entities in their jurisdiction chose to allow this limitation.

Taxing units in 110 CADs offer freeport exemptions. Taxing units in 71 CADs offer the goods-in-transit exemptions.

Certifying the Appraisal Roll

After the ARB completes protest hearings, the chief appraiser must certify the appraisal roll to the CAD's member taxing entities so they can adopt budgets, set tax rates and prepare for the tax collection process. Tax Code Section 26.01 requires the chief appraiser to certify the appraisal roll by July 25. In 2008, 182 CADs met the statutory deadline, and 46 did not. Twenty-three did not respond to this survey question (Exhibit 13).

Exhibit 13
Compliance with Requirement to Certify Appraisal Roll

 Compliance with Requirement to Certify Appraisal Roll

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.

Assessing and Collecting

While all CADs appraise property, some have the additional duties of assessing or collecting property taxes. In 2008, 119 CADs calculated effective and rollback tax rates for 942 local taxing units, 71 published required notices of proposed tax increases by 470 taxing units and 109 prepared and mailed tax bills for 900 taxing units.

One hundred five CADs collect taxes on behalf of 998 taxing units. They budgeted $17.7 million for collections, or an average of $169,921 per CAD performing collections.

Facilities and Computers

Most CADs (222) operate offices under an independent board and chief appraiser. Another 13 CADs make other arrangements, such as having the tax assessor or other offices oversee CAD operations. Eighteen CADs did not respond to this question on the survey.

CADs may own property for use as office space. In 2008, 152 CADs owned office space. Twenty CADs leased office space from a private owner, 38 leased from a taxing entity and 20 enjoyed free use of office space. Twenty-three CADs did not respond to this question on the survey.

Two hundred seven CADs reported contracts for appraisal or collections software services with 13 appraisal firms. Five firms provide services to 91.8 percent of the CADs reporting contracts (Exhibit 14).

Exhibit 14
Top 5 Appraisal Software Vendors, 2008

Outside Appraisal Services Firm Number of CADs Under Contract
True Automation 87
Pritchard & Abbott Inc. 60
Southwest Data Solutions 16
Tyler Technologies 15
Capitol Appraisal Group 12
Total Top Five 190
Total CADs Reporting Contracts 207
Percent Top Five of Total 91.8%

Source: Texas Comptroller of Public Accounts, 2008-09 Appraisal Districts Operations Survey.

There were 154 CADs with a geographic information system (GIS). Reporting CADs entered 74 percent of their appraisal records in the GIS. Forty-seven CADs had entered all their records into GIS, while eight CADs with a GIS had not yet entered any appraisal records into the system. Seventy-four CADs reported that they did not have a GIS and 25 CADs did not answer this question on the survey.

In a separate survey, PTAD obtained information to update names and addresses of CAD directors, ARB members and chief appraisers. This information is contained in the 2009 Appraisal District Directory, available online at www.window.state.tx.us/taxinfo/proptax/apprdir09/.

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