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Chapter 2
Findings of the Appraisal Standards Review

This chapter of the report addresses the findings, commendations and recommendations from the appraisal standards review of the Archer County Appraisal District in five sections:

2.1Board of Directors
2.2Appraisal District Policies, Procedures and Operations
2.3Information Processing Systems
2.4Staffing, Personnel Qualifications and Positions
2.5Generally Accepted Appraisal Practices; Equality and Uniformity of Appraisal Standards

2.1 Board of Directors

The quality of the property tax system depends on the appraisal district's board of directors. Individuals serving on the board of directors bring to the board knowledge, judgment and expertise in establishing policies and procedures for the district's organization and operation.

The appraisal district was formed in January 1981 and became active in 1982. The district board of directors consists of eleven members. Current members of the board are listed in Exhibit 4.

Exhibit 4
Board of Directors Members

Board Member Represents Starting Year
Bill Enlow Archer City ISD 2003
Victor Kocks, Vice Chair Holliday ISD 1994
Paul Wylie, Sec Archer County 1990
Terry Schroeder City of Windthorst 2005
Travis Nelson City of Archer City 1996
Mike Kephart City of Holliday 2003
Lawrence Smith Megargel ISD 1990
Connie Steinberger Windthorst ISD 1982
Glen Tatum City of Megargel 2004
Don Sheppard, Chair City of Lakeside City 1996
Teresa Martin Tax Assessor/Collector 1984
Source: Archer CAD, April 2005.

Paul Wylie is the County Judge and Teresa Martin is the Archer County Tax Assessor-Collector. Bill Enlow is an Archer City ISD board trustee. Victor Kocks is a Holliday ISD board trustee. Lawrence Smith is a Megargel ISD board trustee. Connie Steinberger is a Windthorst ISD board trustee. All are elected officials.

The Board of Directors has the following primary responsibilities:

  • Establish the appraisal district's appraisal office;
  • Adopt the appraisal district's annual operating budget;
  • Contract for necessary services;
  • Hire a chief appraiser to act as chief operating officer;
  • Hire a taxpayer liaison officer (districts in counties having a population of over 125,000);
  • Appoint appraisal review board members; and
  • Make general policy on the appraisal district's operation.

The board of directors received a written survey about board activities. Four of the eleven board members responded. The survey was broken down into board policies and procedures, chief appraiser and staff, property appraisals, appraisal review boards, and budgeting and financial management. The board generally gave itself, the chief appraiser, and staff high marks for running the district. On the majority of questions, the board agreed or strongly agreed that the district was operating effectively. All four board members strongly agreed or agreed with the statement that "the board maintains a comprehensive set of policies and procedures to guide the operation of the appraisal district; and one disagreed with the statement that "all board policies in my district are reviewed and updated at least every two years." The board members felt they did evaluate the chief appraiser annually, and felt they did have a written job description and a performance plan for the chief appraiser. Two board members agreed with the statement that "the external audit contract is periodically bid and the auditors are rotated periodically," as well as the statement "the board regularly monitors the performance of contracts after a contract is signed."

FINDING
Archer CAD's budget lacks the detail necessary to comply with Section 6.06 of the Tax Code and the district did not publish notice of a public hearing on the budget as required by Section 6.062.

Section 6.06 requires a listing of each proposed position including the salary and benefits for the position and each proposed capital expenditure and an estimate of the amount of the budget allocated to each taxing unit. Taxing units are also required to maintain a copy of the budget for public inspection at its principal administrative office.

Section 6.062 requires the district to publish a notice of a public hearing at which the board of directors considers the appraisal district budget in a newspaper having general circulation in the county. The chief appraiser said she did not realize she was supposed to publish the notice. She said she did post an agenda, however, for the meeting at the county courthouse.

Copies of the budgets for 2002, 2003, 2004 and 2005 were reviewed. Each budget contains a listing of each proposed staff position showing its proposed salary. The benefits allocated to each position, however, are shown as category totals rather than itemized for each proposed position. According to the budgets, benefits for fulltime staff include health insurance, retirement, and an incentive pay.

Each budget contains a listing for proposed capital expenditures, but just says "equipment/scanning reserve." Exhibit 5 shows the budgets for 2003, 2004, and 2005. In November 2005 the chief appraiser provided a copy of the 2006 proposed budget, which does include a listing of salary and benefits for each position.

Exhibit 5
Archer CAD 2003-2005 Budgets

  2003 2004 2005
Salaries      
Chief Appraiser $31,000 $32,000 $32,000
Asst. Appraiser $17,500 $18,000 $18,750
Appraisal Clerk $15,500 $16,000 $16,000
Longevity $700 $750 $850
Benefits      
Health Ins. $11,500 $13,000 $13,000
Medicare $1,250 $1,250 $1,250
Retirement $6,000 $6,000 $6,000
Unemployment Tax $1,000 $1,000 $1,000
Incentive Pay $1,500 $1,500 $1,500
Operating      
Maintenance Agreements $1,200 $1,200 $1,200
Office Supplies $4,000 $4,000 $4,000
Postage $5,000 $5,000 $5,000
Janitorial $1,050 $1,050 $1,050
Audit $3,000 $3,000 $3,000
Real Estate Software Contract $11,500 $12,050 $12,050
Mineral Appraisal Contract $58,500 $60,500 $60,500
Mapping Software Maintenance $2,500 $2,500 $2,500
Mapping Update $1,500 $1,500 $1,500
General/Auto Liability $2,000 $3,000 $3,500
Public Official Liability $3,400 $4,000 $4,500
Workmen's Compensation $1,000 $1,000 $1,000
Internet Services $1,000 $1,000 $1,000
Building      
Rent $6,000 $6,000 $9,000
Utilities $6,500 $6,500 $3,500
Building Fund $5,000 $0 $0
Education & Travel      
Dues $1,500 $1,500 $1,500
Appraisal Travel $2,500 $3,000 $3,000
Schools & Seminars $4,500 $4,500 $4,500
Special Services      
Professional Services $1,000 $1,000 $1,000
Board of Directors $1,000 $1,000 $1,000
Appraisal Review Board $1,000 $1,000 $1,000
Capital Outlay      
Equipment/Scanning Reserve $2,500 $1,950 $2,000
Total $213,100 $215,750 $217,650
Source: Archer CAD 2003, 2004, and 2005 budgets.

Boards of directors are required by law to hold a public hearing on the budget. The hearing for the 2003 budget was held on June 27, 2002. The hearing for the 2004 budget was held on June 24, 2003 and the hearing on the 2005 budget was held on June 17, 2004.

Taxing entities and the public need to understand how district employees are compensated. With more than two-thirds of the budget going to wages and benefits, both taxing units and the public need the detail required by state law to be assured the number of staff in the district is sufficient to perform the work and that the staff is correctly compensated.

Subsequent to the review, the chief appraiser said that the 2006 budget for the district complied with Section 6.06 but did furnish the review team with a copy.

RECOMMENDATION 1
Expand the detail of the budget to include the benefits proposed for each position and a list of each proposed capital expenditure as required by Section 6.06 of the Tax Code and post notice of public hearing on the proposed budget as required by Section 6.062.

FINDING
The board does not have a written process for hiring or evaluating a chief appraiser or a written job description. According to the chief appraiser, she has not received an evaluation in the past four years as the chief appraiser. She did, however, receive evaluations prior to becoming the chief appraiser. There is no process for evaluating the chief appraiser. The three board members who returned the Comptroller's survey all agreed, however, that the board evaluates the chief appraiser annually, that the appraisal is formally documented with measurable criteria and that there is a job description for the chief appraiser and a performance plan for measuring the chief appraiser's performance. The fourth member did not agree that the evaluation was formally documented with measurable criteria.

All the board surveys agreed that the board has confidence in the chief appraiser and the chief appraiser is doing the job.

Chief appraisers are responsible for ensuring that competent staff is hired, procedures are documented, appraisals are performed, employees are evaluated and all other functions performed by an appraisal district. Having a qualified chief appraiser is important to effective district operations.

Without written guidelines for the chief appraiser to follow, an objective evaluation of the chief appraiser's performance is impossible. No documentation on the chief appraiser's performance was provided to the reviewer.

Without an objective system in place to ensure that the board and the chief appraiser are in agreement as to what is expected of the chief appraiser, performance evaluations may be subjective and based on emotion rather than actual performance.

In Nueces CAD, for example, the board has developed a well-defined job description for the chief appraiser and constructed an objective evaluation tool for measuring the chief appraiser's job performance. The chief appraiser's job description contains the statutory responsibilities set forth in Section 6.05 of the Tax Code, as well as specific goals and expectations required from the board. The job description clearly defines the role of the chief appraiser and lays the groundwork for an objective evaluation. The chief appraiser receives an annual performance evaluation on the anniversary date of his/her hire. The board uses an instrument that allows for input from all board members, and affords the chief appraiser an opportunity to address his/her own goals and objectives during the evaluation period. In addition, the evaluation sets up goals and objectives for the next twelve months. Having an objective evaluation system in place ensures that the board and the chief appraiser are in agreement as to what is expected of the chief appraiser, and eliminates performance evaluations that may be subjective and based on emotion rather than actual performance.

After the onsite visit, the chief appraiser said that the board was going to evaluate her in December.

RECOMMENDATION 2
Develop a job description and an objective set of evaluation measures for the chief appraiser position and establish an annual evaluation process based on objective measures.

FINDING
The appraisal district's contract for appraisal services with the Pritchard & Abbott, Inc. (P&A) for professional appraisal services, on-line data processing and for mapping software and maintenance does not include the dates when services will be delivered to the appraisal district nor does it contain any monitoring provisions. The contract also does not include the dates when the contract begins and ends and does not include a venue clause. Venue clauses are common in government contracts, establishing the location of courts that would be used in the event of a contract dispute. All three contracts were signed September 10, 2003 by the chief appraiser and P&A for 2004 and 2005. The contracts for 2003 were not made available; the contract reviewed was for 2004 and 2005. The district pays P&A $60,500, $12,050 and $2,500 respectively, paid in equal quarterly payments. An automatic option for contract extension is in effect for 2004 and 2005 unless the CAD gives written notice of its intent not to exercise the option.

According to the professional appraisal services contract, P&A is to appraise all interests in properties producing oil, gas, coal, or other hydrocarbons, and hard minerals, including working interest, oil payments, overriding royalties and royalty interests; and shall also include all personal property related to oil and gas production such as oilfield supply stores, oilfield service companies, pipe yards, oil company production yards, drilling equipment, dirt contractors, etc. The contract specifically excludes sand, gravel, caliche and all other non-fuel minerals.

Also included within terms of the contract is utility property such as pipelines, pump stations, compressor stations, railroad, water systems, cable television systems, electric systems, telephone systems, and gas distribution companies. Real and personal property associated with heavy industries and major manufacturing plants are included.

The contract establishes what records the appraisal firm will provide the district, including one copy of the appraisal records, two copies of notices of appraised value, one copy of the appraisal roll, one copy of the appraisal roll for each of the taxing units and one copy of division orders listing all current record owners of interests in oil and gas.

In order to get the appraisal roll ready each year, the appraisal district should have all of the appraisal information complete and in the appraisal district system before the appraisal notices are run. Without dates for specific deliverables, the district would have no recourse to compel the vendor to perform the services within a prescribed timeframe.

IAAO's Standard on Contracting for Assessment Services, Section 4, requires contracts have specific provisions, including the timeframes when services or goods will be delivered.

Good procedures identify the contract monitor and the duties that the contract monitor is to perform for each contract. Without contract monitoring, the district cannot make a decision on the quality of services rendered by the contractor.

IAAO's Standard on Contracting for Assessment Services, Section 5, requires monitoring contract performance.

RECOMMENDATION 3
Revise all contracts to include detailed description of the work to be performed, deliverable dates and establish contractual provisions and procedures for monitoring contracts.

2.2
Appraisal District Policies, Procedures and Operations

In organizing and administering an appraisal district, the chief appraiser is responsible for hiring, firing, and training personnel, for ensuring compliance with a wide range of legal requirements and for the maintenance of policies and procedures for effective appraisal district office operations. The district is also required to comply with Comptroller rules concerning application forms and appraisal records.

The chief appraiser is required by law to prepare and certify an appraisal roll for each taxing unit participating in the district. Certification of the appraisal roll for the 2003 tax year by the district was completed according to the law.

FINDING
Archer CAD does not have policies and procedures to guide the day-to-day operations of the district in areas such as payroll processing, accounting, purchasing and the like. The chief appraiser is responsible for payroll processing, accounting and purchasing.

Instead of documented policies and procedures, the chief appraiser handles the administrative function of the office. It is not clear how certain policies are translated into practice in the district, nor is it clear that the chief appraiser or any other employee is responsible for monitoring day-to-day operations to insure that policy decisions of the board are carried out.

A policy tells a person, department, or group of individuals what they must do, whereas as procedure enumerates how it can be accomplished.

Well-written and organized procedures:

  • implement and assure compliance with board policies as well as documenting the intent of those policies;
  • protect the institutional knowledge of an organization, so that as experienced employees leave, new employees have the benefit of the others' years of experience;
  • provide the basis for training new employees; and
  • offer a tool for evaluating employees based on their adherence to procedures.

In the absence of well-documented procedures and policies, the work of the appraisal district may come to an abrupt stop if key personnel leave a position as a result of sudden illness, death or other personal tragedies. Other examples abound in other organizations of whole departments without trained back-ups for critical positions like payroll, and of poor training techniques that show new employees how to perform a task, but not why.

To be effective, policy and procedure manuals should be updated and kept current at all times. This means setting up a system for regular updates and distribution, as well as periodic reviews to ensure that all old policies are removed when no longer needed.

The Jefferson county appraisal district, for example, recently reviewed by the Comptroller's office, maintains a current and comprehensive policy and procedure manual detailing procedures for payroll, accounting, purchasing, budget, travel, bank reconciliations and similar procedures.

RECOMMENDATION 4
Develop a comprehensive written policy and procedures manual for administrative operations.

2.3
Information Processing Systems

Appraisal districts use information technology to provide detailed records that are easily accessible to staff and the public. Information technology systems allow staff to effectively manage large amounts of data on individual properties and make the appraisal process more efficient.

FINDING
Archer CAD has an appraisal system that meets statutory requirements. Archer CAD contracts with Pritchard & Abbott (P&A), Inc. of Fort Worth, Texas for: software (Deed mapping, Bentley Products, MicroStation Products & GeoGraphics, & TMC database software applications, etc.); hardware (one data processing controller, one telephone modem, and one telephone line); maintenance; and technical support.

P&A provides on-line data processing of real properties. More specifically, they provide Archer with: appraisal record maintenance, appraisal calculations (land & building appraisal), sales information, tax roll and billing information, appraisal notices (real and minerals), electronic data submission to the Comptroller's Office, real estate state property tax board reports, and a CD-ROMS (R.E. appraisal roll to appraisal district, appraisal notices, appraisal cards, mineral division order, mineral appraisal roll, and a detailed inventory of business personal property).

When new appraisal data needs to be entered into the information processing system, staff can do so from the comfort of their offices using a PC. When appraisal information needs to be printed off the staff can do so from the printer in their office.

Archer has an appraisal history database on-line and on CDs starting from 1992 through 2005. This on-line system is supported by P&A. CDs are used to back up all data and extra copies of the CDs are stored in the CAD's vault. The CAD no longer stores paper copies of appraisal cards. When appraisal cards are needed they are printed off.

The CAD completes an appraisal notice checklist and sends it to P&A annually. This process is used to ensure that Archer receives all of its annual property appraisal notices and that the appraisal notices are mailed out in a timely manner.

COMMENDATION
Archer CAD has a fully operational information processing services that staff members know how to operate.

2.4
Staffing, Personnel Qualifications and Positions

Personnel and human resources management are a critical function of appraisal districts. Successful management of personnel includes efficient recruiting, hiring, classification and compensation, benefit administration, training and development, and performance evaluation. Compliance with equal employment opportunity statutes and other applicable federal and state laws and the establishment of fair and workable policies, procedures and training are important for the recruitment and retention of competent staff.

The Archer CAD staff is organized as outlined in Exhibit 6.

Exhibit 6
Archer County Appraisal District Staff Positions, Certifications, Years with Archer CAD and Salaries

Position BTPE Certification Years with Archer CAD Salary
Chief Appraiser RPA & RTA 14 $33,000
Assistant Chief Appraiser Class II-A 3 $19,400
Appraisal Clerk - 5 months $16,500
Source: Archer CAD, April 2005.

Appraisal district staffs who appraise property are required to be Registered Professional Appraisers (RPA) or to be working towards certification as an RPA. Staff must be certified within five years of their hire date. Interim certifications include Class II and Class III. In addition, RPAs must re-certify five years from the date of first certification and every five years while registered.

The district provides appraisal services for the following ten taxing units: the Archer County, the Archer City Independent School District, the Holliday Independent School District, the Megargel Independent School District, the Windthorst Independent School District, the City of Archer City, the City of Holliday, the City of Lakeside City, the City of Megargel, and the City of Windthorst.

FINDING
Currently there is no provision for written employee performance evaluations of Archer CAD staff. Job descriptions have not been reviewed and updated since the last chief appraiser left the district. Written performance evaluations, at a minimum of once each year, provide for the continuing development of district employees as well as establishment of goals and objectives clearly understood by employee and employer. Subsequent to the onsite visit, the chief appraiser said she evaluates new staff after 90 days and would have evaluated the staff regularly, but most have not lasted a year on the job. She said she has evaluated the one staff member who has been with the district for three years, but furnished no evidence of the evaluation.

Property Appraisal and Assessment Administration in Chapter 16, "Administration," states, "Although employees may improve their skills by their own efforts and the help of peers, managers have organizational responsibility for employee development. They use training, education, counseling, and performance reviews to identify talents and help employees grow."

In Nueces CAD, for example, employee's performance of assigned duties and other job-related criteria provides the basis for an annual (at a minimum) employee evaluation. Employees are informed of the criteria on which they will be evaluated. Evaluation and performance appraisal ratings are based on the evaluation instrument and cumulative performance data gathered by supervisors and the chief appraiser throughout the year.

Each employee has at least one evaluative conference annually to discuss the written evaluation and may have as many conferences about performance of duties as the chief appraiser deems necessary. Evaluation records and forms, reports, correspondence and memoranda are placed in each employee's personnel records to document performance. All records that support appraisal ratings are maintained for at least two years. Official appraisal records are then maintained throughout a person's employment with the district and for two years after an employee ceases to be employed with the district. All employees receive a copy of their annual written evaluation.

RECOMMENDATION 5
Adopt a policy to be incorporated into the personnel manual providing for annual written employee performance evaluations for all employees of the appraisal district and develop written procedures for evaluating staff.

FINDING
Archer CAD's parcel to staff ratio is higher than its peer districts appraising the same number of accounts and its salary ranges are lower than its peer districts. The CAD has eleven taxing entities for which appraisals and reappraisals are conducted. The CAD has 17,152 property parcels with 10,689 being real property parcels, 6,095 being mineral parcels, and 368 being personal property accounts. The CAD office has one certified appraiser, one appraiser working to get certified, and one appraisal clerk. Because of safety issues, two appraisers go into the field to conduct appraisals and reappraisals. With a staff of three if anything unexpected happened to one of the appraisers, the district would have difficulty maintaining their appraisal and reappraisal schedules.

Exhibit 3 in chapter 1 shows that the staff per local parcel ratio in Archer is 1 to 3,434, compared to the peer group average of 1 to 2,615. The IAAO standard for a small appraisal office is 1,500 to 1,700 per staff person. The three peer districts closest in over size are Floyd, Mason and McCulloch. They have a staff to local parcel ratio of 1:2,127, 1:2,718 and 1:2,991, respectively. The chief appraiser's annual salary is 28 percent lower than the group average and staff salaries are 25 percent below peer group salaries at the low end and 35 percent below salaries at the high end.

Also, Archer CAD does not have an employee who is responsible for fulfilling the mapping duties and associated appraisal responsibilities involved. The chief appraiser has taken on this responsibility.

While P&A provides a CD with aerial shots of real property in the district, the chief appraiser functions as the CAD's mapper. She learned the mapping functions many years ago while a staff member in the district and still performs all mapping functions for the CAD, which takes her away from the managerial duties of a chief appraiser.

The chief appraiser manages the staff; handles mapping details; performs all real property appraisals; handles and monitors all contracts; develops the budget and maintains the finances of the district; and performs all of the other duties of the chief. If anything happened to the chief appraiser, the district would have difficulty meeting the Comptroller's mandated deadlines and statutory deadlines. There would not be sufficient depth of knowledge and breadth of experience in the current appraisal staff to maintain the normal functioning of the office.

RECOMMENDATION 6
Conduct a staff needs analysis and establish staffing allocation guidelines that will ensure that the number and type of staffing is appropriate and annually adjusted to meet reappraisal plan goals each year.

2.5
Generally Accepted Appraisal Practices; Equality and Uniformity of Appraisal Standards

There are three approaches to value - cost, income, and market - that a chief appraiser must consider in determining the market value of property. The chief appraiser must consider all three and use the method most appropriate in appraising a particular property.

FINDING
Archer CAD lacks a detailed reappraisal plan to ensure the execution of timely and accurate reappraisals.

The Archer CAD reappraisal plan for 2003 and 2004 was a one-page statement about reappraisal work that is expected to be performed during the year. The reappraisal plans are very general in nature. P&A is listed as performing the appraisal of mineral accounts in each school district. The chief appraiser said the board adopts the reappraisal plan annually.

The written reappraisal plan does not give any detail as to the steps to be performed, staffing levels, workflow or the costs associated with plans and goals. The plan does not discuss how market areas might be grouped to provide sufficient sales for appraisal model analysis and development.

The reappraisal plan does not link the appraisal district's budget, training, contracting, market analysis, field inspections and data processing in one document. The appraisal district's policy includes statements about some of these elements but the appraisal district's board of directors has not adopted a plan that includes documentation of how the appraisal district staff will implement the reappraisal plan. In addition, the board of directors has not adopted or reviewed the work plan the staff would follow to accomplish the reappraisal policy.

Lack of a detailed reappraisal plan could cause the execution of the plan to go awry, and result in property values that deviate from market value. This market value deviation could cause any of Archer County's school districts to receive an invalid finding in the state's property value study.

Section 25.18, Tax Code, requires appraisal districts to implement a plan for reappraisal. The plan for reappraisal shall provide for reappraisal of all real property in the district at least once every three years. A reappraisal plan is a roadmap for performing the work. It is also a communication tool that shows the appraisal district board of directors how the appraisal district staff plans to accomplish its appraisals, and if the board chooses to require the chief appraiser to submit the plan for approval, the board can direct the appraisal activities by amending the plan.

According to USPAP Standard 6, a functional reappraisal plan includes the following activities:

  • identifying properties to be appraised;
  • identifying and updating in the appraisal records the relevant characteristics of each property to be appraised;
  • defining market areas;
  • identifying property characteristics that affect property value in each market area;
  • developing an appraisal model that reflects the relationship among the property characteristics affecting value in each market area;
  • calibrating the model to determine the contribution of the individual property characteristics affecting value;
  • applying the conclusions reflected in the model to the characteristics of the properties being appraised; and
  • reviewing the appraisal results.

The USPAP, Standards Rule 6-2(g), requires appraisers to "identify the characteristics of the properties that are relevant to the purpose and intended use of the mass appraisal, including:

(i) the group with which a property is identified according to similar market influence;
(ii) the appropriate market area and time frame relative to the property being valued; and
(iii) their location and physical, legal, and economic characteristics."

To comply with this standard, appraisal districts typically record property characteristics that include: the Comptroller's property category code, the location and market area of property; the physical attributes of the property such as the size, age, condition, and construction type; the number of various kinds of rooms such as bedrooms, bathrooms, etc.; the presence of amenities such as central air conditioning; any legal and economic attributes or restraints; and the presence of easements, covenants, leases, special appraisals, ordinances or other legal restrictions. See the Comptroller's Electronic Appraisal Roll Submission Record Layout and Instruction Manual.

A reappraisal plan also provides for a physical inspection of the properties being appraised. Alternatively, the plan can include reliance on reliable sources of property information instead of physical inspections. Such sources include: deeds or other legal documentation, aerial photographs, land-based photographs, surveys, maps and property sketches. A complete plan would indicate instances or types of properties that will be appraised using sources of information other than physical inspection.

RECOMMENDATION 7
Adopt a detailed reappraisal plan that, at a minimum, includes the vital steps in the process, explains exactly how and when the steps will be executed, and explains how sufficient resources will be allocated to follow the plan.

FINDING
The appraisal district lacks detailed written appraisal procedures manuals for the appraisal staff.

Subsequent to the onsite work the chief appraiser said that the district does have an appraisal manual and each staff member has a copy, but the chief appraiser did not furnish a copy for review.

The CAD uses the Marshall & Swift manual as the source for building the residential and commercial appraisal schedules. This manual is widely considered by appraiser professionals as the authority in cost appraisal. However, the manual does not contain information about local procedures and directives for completing appraisals in Archer. Each CAD must determine sale prices in order to develop a local modifier or an adjustment factor. When this process is followed residential and commercial properties are then considered to be "market adjusted."

The appraisal records are kept current with the new deed records being received each week and deed changes being made within a month.

The appraisal district uses an automated valuation model computer appraisal system. Through fieldwork, the appraisers gather specific information about properties such as condition of the property, age of the property, construction details, and physical dimensions. In addition, the appraisers gather information about the land on which real property is located. They gather specific information about the dimensions of the land, its shape and location. The appraisers gather the same information for vacant land, whether a vacant lot or a rural tract.

Personal property inspections are done at least once every three years. Personal Property renditions are mailed to the business each year. The chief appraiser and other appraiser reviews renditions for reasonableness by comparing the rendered values to the personal property value schedule in the Comptroller's field appraiser's guide.

Lack of detailed appraisal procedures manuals could cause inconsistent appraisals and result in property values that deviate from market value. This market value deviation could cause any of Archer County's school districts to receive an invalid finding in the state's property value study. As mentioned previously, Holliday ISD did receive an invalid finding in the Comptroller's 2003 Property Value Study, and an invalid finding, if uncorrected, could eventually cause the school district to receive less funding from the state than expected. Further, if the level of appraisal (percentage of market value) varies from school district to school district, or from taxpayer to taxpayer, some taxpayers could be bearing more than their fair share of the local tax burden.

Section 23.01, Tax Code, mandates that property be appraised by applying generally accepted appraisal methods and techniques. This section also requires appraisal districts to comply with the USPAP and requires similar appraisal methods and techniques be applied to the same or similar properties, while taking care to account for the contributions of individual property characteristics on value. A comprehensive appraisal procedures manual would help ensure that these standards and requirements are attained.

RECOMMENDATION 8
Prepare and issue to each appraiser detailed appraisal procedures manuals that provide local procedures and practices for each type of property the staff appraises and tie these local procedures to the existing Marshall & Swift procedures.