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Chapter 2:
Findings of the Appraisal Standards Review

This chapter of the report addresses findings and recommendations from the appraisal standards review of the Bailey CAD.

Key Findings and Recommendations

As part of the review process, PTAD makes recommendations to address challenges identified during its review of a CAD. Below are recommendations addressing key challenges associated with Bailey CAD's appraisal activities.

FINDING
Bailey CAD's written reappraisal plan does not include sufficient information to meet the planning and operating needs of the appraisal district and does not meet Property Tax Code, USPAP or IAAO requirements.

After review of the draft report, the chief appraiser stated, "I could not find in S.B. 1652 passed in 2005 that the reappraisal plan needed to be comprehensive. The Mass Appraisal Report is more comprehensive. I will rewrite our plan with more detail."

Property Tax Code Section 25.18 states:

USPAP Standards, Rule 6-2(g), requires appraisers to identify the characteristics of the property that is relevant to the purpose and intended use of the mass appraisal. To comply with this standard, appraisal districts typically record property characteristics that include the:

• Comptroller's property category code;
• location and market area of property;
• physical attributes of the property such as the size, age, condition and construction type;
• number of various kinds of rooms such as bedrooms, bathrooms, etc.;
• presence of amenities such as central air conditioning;
• legal and economic attributes or restraints; and
• presence of easements, covenants, leases, special appraisals, ordinances or other legal restrictions.

The IAAO textbook, Property Appraisal and Assessment Administration, Chapter 13, Mass Appraisal, states that the required activities for all reappraisals must include the following steps in the order given:

• Performance Analysis – Determines whether or not the values are consistent with the market and if the values are equitable and that ratio studies are the primary tool for the analysis.
• Reappraisal Decision – Use statutes or administrative rules. This may include a cyclical schedule in which jurisdictions are physically reviewed and revalued. It is also noted that the reappraisal requires careful planning along with a major commitment of resources.
• Analysis of Available Resources – This step is performed before defining goals and objectives. This includes evaluating the staff, budget, existing systems and practices, data processing support and existing data and maps. The publication also stresses that an adequate budget is crucial in that it can overcome deficits in other areas.
• Planning and Organization – IAAO emphasizes that this is the most important aspect of reappraisal as it identifies the target completion date and performance objective, specific plan of action and timeline. The plan should also include definitions of critical activities with completion dates, assignment of responsibilities, and establishes data collection and field work standards.
• System Development – This produces the procedures, methods, manuals, and software for the mass appraisal system.
• Pilot Study – This study tests procedures in several portions of the jurisdiction. It should include a ratio study to verify if the system produces reliable and accurate values and point out needed modifications.
• Data Collection – After procedures and forms are made, tested and approved the data collection can start. IAAO stresses that quality control is essential.
• Production of Values – This begins with a market analysis, model development, model calibration and calculation of preliminary values. The ratio study then assesses the consistency and validity of the values between each property type and area. After the models provide acceptable results, they can be used to produce values.
• Preparation of Appraisal Roll.
• Final Performance Analysis.
• Data Maintenance.
• Value Updates.

Property Tax Code Section 6.05(i) requires an appraisal district board to develop a biennial written plan for the periodic reappraisal of all property within the appraisal district boundaries and to hold a public hearing to consider the proposed plan. Each appraisal district must implement a plan that provides for the reappraisal activities for all appraisal district real and personal property at least once every three years.

Bailey CAD developed its reappraisal plan for tax years 2007 and 2008 in August 2006. The board held a public hearing on Aug. 17, 2006, and adopted the plan during the regularly scheduled meeting following the public hearing. The CAD sent the plan to its five taxing units following approval of the plan. The taxing units in the CAD are Muleshoe Independent School District, the City of Muleshoe, Bailey County, Muleshoe Area Hospital District and the High Plains Water District. Bailey CAD encompasses 827 square miles and about 9,500 parcels.

Bailey CAD staff includes a chief appraiser who also serves as the tax assessor/collector for the five taxing units in the CAD, a deputy appraiser/collector and a collections supervisor. At the time of the onsite visit, the CAD had an additional appraiser position vacant. The CAD uses an outside appraisal firm to conduct appraisals of residential and rural real property. The last reappraisal before the adoption of the CAD's first formal reappraisal plan was in 2005.

Bailey CAD's reappraisal plan is an eight-page document that lists many of the elements addressed by the Property Tax Code, USPAP and IAAO requirements. However, it does not describe how these elements are implemented in the CAD. Sections of the plan briefly address topics such as performance analysis, the reappraisal cycle, analysis of available resources, planning and organization, the mass appraisal system, pilot study, data collection, valuation, mass appraisal report and value defense. District appraisal activities related to real property, personal property and mobile homes are briefly described. The sections do not contain sufficient details to "provide for" a reappraisal because they do not describe how the reappraisal activities will be performed, the resources (internal or external) that are allocated or the specific timelines and markets that will be reviewed.

There are inconsistencies between statements in the plan and actual CAD operations related to the timing of reappraisals and staffing. The plan states that Bailey CAD will conduct a complete reappraisal of all property in the district every year and will update property values as necessary, but the chief appraiser indicated that they reappraised every three years until 2005, when one of the appraisers was killed in a car accident. The chief appraiser stated that when she wrote the reappraisal plan in 2005, "I put in there we would do it every year since we did business personal, autos and mobile homes every year anyway. At that time, the Board of Directors decided to hire another contractor until I could get someone hired and trained."

The CAD employs an outside appraiser to appraise new construction and changes to improvements, as well as one half of the real property in the CAD each year. The chief appraiser indicated she plans to reappraise the other property, but also stated that she did not have the time to do it all and that pictures do not always get taken and pasture and crop land are not always looked at, but improvements are. The chief appraiser indicated that the CAD performs ratio studies each year but was not able to document how they are used to develop the reappraisal plan activities. After review of the draft report, the chief appraiser stated, "I told them and showed them that I can run ratios for any date or any class any time, so I don't keep the paper copies. I think it is unnecessary to have an Excel spreadsheet of what the computer will generate at any given time. I study the ratios to determine where the problems are with the sales. I can't help what the on site reviewer does with the appraisals."

The portion of real property to be physically inspected is not identified in the reappraisal plan or in the contract with the outside appraiser. The chief appraiser stated that "the parcels are determined at the time of scheduled work." The plan refers jointly to the CAD appraisers and outside appraisers, but does not address their roles or use of another appraisal firm that performs the reappraisals of industrial and utility property. A reappraisal plan was provided for one vendor, but the chief appraiser indicated the other vendor uses the CAD's reappraisal plan.

In addition, the reappraisal plan also does not identify the property characteristics affecting property value in any area of the district. The plan does not identify any market areas, such as the city of Muleshoe. The chief appraiser stated "We are small, the market areas are Real, Personal Autos and Mobile Homes." For residential property, the plan does not identify any factors, such as location, traffic and size that affect the land appraisal component. After reviewing the draft, the chief appraiser stated, "We are small, these are really not relevant." The 2006 COD for Bailey CAD Category A was 17.17 and 30.59 for Category D. These high CODs indicate relative inconsistency or lack of uniformity among appraisals in these categories in Bailey CAD. Development of market areas and schedules will assist in reduction of variability among appraisals. The plan does not identify similar factors for the building component such as size, age, condition or construction type. Similarly, the plan does not identify the relevant characteristics of each property to be appraised and how the district's appraisal records will be updated with the characteristics.

With respect to timelines, the plan simply states that the "office follows the Property Tax Calendar as published by the Texas Comptroller of Public Accounts." No calendar is provided. Subsequent to the review, the chief appraiser provided a one-page reappraisal calendar that generally describes actions that occurred in the prior year, January through March, April through May, June and July. It does not provide any indication as to when certain market areas will be reappraised nor does it discuss who has responsibility for the tasks.

A reappraisal plan that provides for a reappraisal explains how and when the appraisal district plans to perform each of the required activities. A well-executed reappraisal plan ensures that each school district's values are valid in the PVS, so the school districts receive their appropriate amount of state funding. The plan uses ratio studies and other data to identify property that needs to be reappraised in a timely manner to limit the occurrence of invalid values.

Without an effective reappraisal plan, an appraisal district may not reappraise property in either a consistent process or on a timely schedule. This lack of adjustment or timeliness may result in values that are not adjusted to reflect the market and values that are inconsistent across property categories or neighborhoods.

After review of the draft report, the chief appraiser stated:

But if there are no sales it is the on site reviewers call in their appraisals. Without sales, who knows what the market is.

In areas where sales are scarce or difficult to verify, IAAO suggests expanding the time period for which sales are analyzed, but cautions that older sales must be adjusted for time to ensure consistent results.

Jefferson CAD, for example, has adopted a comprehensive reappraisal plan that ensures the execution of timely and accurate reappraisals on an annual basis. The CAD reviews the plan each year and updates it as needed. The reappraisal plan is a part of the CAD's policy and procedures manual adopted by the board. The plan gives details regarding the steps to perform, staffing levels, workflow and the costs associated with plans and goals. The CAD links the plan to its budget, training, contracting, market analysis, field inspections and data processing. The board adopted or reviewed the reappraisal plan and makes changes as necessary.

RECOMMENDATION 1
Adopt biennially a comprehensive written reappraisal plan that addresses the planning and operating needs of Bailey CAD and meets Property Tax Code, USPAP and IAAO Standards.

The reappraisal plan should describe the specific responsibilities of the external appraisal firms used for reappraisals and how their work will be monitored and assessed.

FINDING
Bailey CAD does not have documented procedures to ensure consistency in the performance of appraisal activities and the development of valid values for all property categories.

Property Tax Code Section 23.01(b) states:

The market value of property shall be determined by the application of generally accepted appraisal methods and techniques. If the appraisal district determines the appraised value of a property using mass appraisal standards, the mass appraisal standards must comply with the Uniform Standards of Professional Appraisal Practice. The same or similar appraisal methods and techniques shall be used in appraising the same or similar kinds of property. However, each property shall be appraised based upon the individual characteristics that affect the property's market value.

IAAO's Property Appraisal and Assessment Administration, Chapter 1, "The Ad Valorem Tax System," describes the importance of written procedures or standards of practice and states they may incorporate or be contained in laws, regulations, policy memoranda, procedural manuals and guidelines, appraisal manuals and schedules. Repeated tasks, particularly those done by more than one person, should be described in guidelines or manuals. There should be a procedure for
establishing standards of practice, including regularly updating manuals. Procedures are required for monitoring the quality of appraisals, editing data and reviewing appraisals.

The chief appraiser indicated that the appraisal district does not have written manuals in place. Instead, the appraisal district relies on the experience and judgment of the chief appraiser, who has been in this position for 13 years and the experience of the outside appraisers who perform the bulk of the inspections of both residential and rural real property. New appraisers are trained by working with the chief appraiser until she is satisfied that they understand the process.

Each year, an outside appraiser appraises all new and altered improvements, appraises all land developments requiring new appraisal, prepares a new agricultural value schedule and appraises 50 percent of the remaining real parcels as agreed upon by the appraisal district and the outside appraiser. Through fieldwork, the outside appraiser inspects each property and gathers specific information, such as the property's condition, age, construction details and physical dimensions. Land values are not changed every year. The outside appraiser records the accumulated property characteristics on appraisal cards and draws diagrams of all improvements. Using the CAD's residential and rural real property schedules and his experience and judgment, the outside appraiser determines the property type and class, unit costs and depreciation. The chief appraiser enters the data gathered in the field into the CAD's automated appraisal system.

Another outside appraiser appraises utilities and industrial property. The CAD has no minerals property.

Residential property is appraised using cost schedules based on Marshall & Swift cost information. The residential schedules, updated in 2007, include building schedules and descriptions of typical classification characteristics. However, the costs used by the chief appraiser for new homes in the city of Muleshoe are outside of the current schedules. The CAD does not have manuals that provide adequate, detailed instruction on how to use the schedules to perform appraisals or representative pictures for each residential class.

Bailey CAD uses the sales comparison approach to establish its schedules for residential property (with very limited sales reported). In theory, they also use this approach to establish land values (rural and urban), but the chief appraiser indicated that some of the urban schedule has not been adjusted for a number of years. The rural schedule, however, appears to be more current. Agricultural values are calculated based on state-recognized norms, regardless of local data. The cost approach is used for commercial improvements (Marshall & Swift) because there is a lack of sales. There is very limited use of the income approach. Personal property appraisal is attributed to state-supplied tables.

During the course of the ASR, the onsite reviewer examined 31 randomly selected properties within the eligible school district from the CAD's 2006 PVS. Seventeen Category A: Single-Family Residences, four Category D: Rural Real, five Category F1: Commercial Real and six Category L1, Commercial Personal properties were audited. The reviewer conducted onsite visits to the property and recreated the values using the CAD's appraisal manuals and oral instructions from the chief appraiser.

With the assistance of the chief appraiser, the reviewers conducted an onsite inspection of each property. Information pertaining to property characteristics contained on the CAD's appraisal cards was examined for accuracy. Age, condition and size were reviewed for reasonableness. The reviewer found that improvements had not been updated in two cases. In all but two cases, the year built and/or effective age was missing for the real property inspected. Informal procedures were used to adjust depreciation, such as 10 percent added depreciation on all known rental property. The review team was unable to determine how economic neighborhood adjustments were determined or applied. After reviewing the draft report, the chief appraiser stated, "We don't have economic neighborhood adjustments. The condition and percent of life left in the improvement determines adjustments in Bailey County."

At the time of the onsite visit, the chief appraiser indicated in her interview that there were no schedules for depreciation and the land values for residential property had not been updated in more than 20 years. After reviewing the draft report, the chief appraiser stated, "Land values have been updated. I don't understand where that came from. Out of a 2 hour conversation, one sentence was taken and put in this report. The special one acre tracts had not been changed in about that long. And some residential lots that has not had any activity in some of the older areas has not been changed." The chief appraiser also provided copies of schedules, but review of these materials indicates they are dated 2006 and are not current. The schedules provide a cost-per-front foot, but no criteria for application. They do not appear to be tied to any classification system, making it difficult to determine how the schedules are applied to individual properties.

The same methods were used to recreate values for four Category D: Rural Real and five Category F1: Commercial Real properties. The physical locations of the four personal property accounts in Category L were viewed but were not physically inspected. Because of these factors, the onsite reviewer was unable to recreate values for property in the selected sample.

A comprehensive appraisal manual outlines the steps appraisers need to perform during fieldwork to gather specific information about property such as the age, condition, construction details and physical dimensions of the building or the dimension, shape and location of the land on which the real property is found. Documented appraisal procedures are particularly helpful in appraisal districts, such as Bailey CAD, that rely on outside appraisers to perform many of the appraisal activities. It is also helpful as a training tool for new or inexperienced appraisers.

Without documented appraisal procedures, the chief appraiser may not be able to ensure that field work is performed consistently or that all needed information is gathered about each property. The review of specific account records indicated that depreciation, year built and effective age were missing in more than 56 percent of the records. If the level of appraisal (percentage of market value) varies between property categories, or from taxpayer to taxpayer, some taxpayers may bear more than their fair share of the local tax burden. In addition, instructions on how to use the CAD's appraisal manuals will help taxpayers better understand the appraisal process.

An appraisal manual is one of the most effective training tools for new appraisers. The lack of a manual forces the chief appraiser to train new appraisers by having them work with the more experienced appraisers to learn appraisal steps in a manner that does not ensure a thorough understanding of the steps or a consistent approach. An appraisal manual in conjunction with training by the chief appraiser will enhance the training environment.

Jefferson CAD, for example, has a detailed appraisals manual to ensure that its staff consistently follows proper procedures in appraising property. The manual outlines the steps for appraisers to follow in gathering specific information about property
and the land on which it is located. The CAD's supervising appraisers use the written appraisal procedures manual to teach the appraisal staff how to be consistent property appraisal. The appraisal procedures manual is also useful as evidence during appraisal review board hearings and for demonstrating that the district is complying with its own policies.

RECOMMENDATION 2
Develop complete appraisal manuals that incorporate generally accepted appraisal standards for use in performing uniform market-value appraisals of all property categories, and use the procedures in a phased approach to reappraise each property in the CAD.

The chief appraiser should ensure that the procedures address the lack of formal depreciation schedules, missing relevant characteristics and the timely review of land values.

Each property should be revisited to ascertain the effective age, and to apply economic or neighborhood adjustments in a uniform manner.

FINDING
Bailey CAD does not effectively use ratio studies to measure appraisal performance.

The IAAO Standard on Ratio Studies points out that two major aspects of appraisal accuracy are level and uniformity. Level refers to the overall ratio of appraised values to market values, while uniformity refers to the degree to which different property are appraised at equal percentages of market value. The standard also provides "recommendations on the design, preparation, interpretation and use of ratio studies for equalization, the evaluation of appraisal performance and the quality control operations of an [appraiser's] office." Finally, the standard provides for design considerations and outlines the six steps generally involved in ratio studies:

Ratio studies compare the market value of individual property in a representative sample of similar property to the local appraised value for each property in the sample.

The Bailey CAD chief appraiser ran three years of internal ratio studies while the review team was on site, but was not able to document how the studies were used to adjust CAD property schedules or to prioritize property categories or market areas for reappraisal.

She stated that she reviews sales before entering them into the system and eliminates sales that appear unreasonable and not arms length transactions, such as sales between family members. The appraisal district does not have an MLS service or other sales data services due to its remote location, approximately 70 miles northwest of Lubbock on the New Mexico border.

Sales information is limited. The district sends sales verification letters to buyers after identifying deed changes in the County Clerk's office. The chief appraiser also obtains some contract sales prices from fee appraisers. The chief appraiser indicated there are about 50 transactions per year, of which 20-25 are considered arms-length. A review of the sales verification letters for the past two years showed 40 arms-length responses for 2006 and 30 similar responses for 2007.

The appraisal district has had an influx of dairy farmers relocating from California, beginning in 2003. This influx has driven up the cost of both rural land and residential property in portions of the city of Muleshoe. The chief appraiser indicated she was initially reluctant to include these sales because there were so few and not typical of traditional sales prices for the area. Not including these sales appears to be the most important cause of the invalid PVS values. She indicated that she began including these sales in the ratio studies in 2007.

The major aspects of appraisal performance evaluations are the appraisal level and appraisal uniformity. The appraisal level refers to the percentage of local appraised values that represent market value and is determined by dividing the local appraised value by the market value. Indicators of market values may be either sales or independent, expert appraisals. Appraisal uniformity refers to the degree to which property is appraised at equal levels. Uniformity is typically represented by a statistic COD. The COD measures the average variation in appraisal levels from property to property or among property types and is calculated from a statistical formula that incorporates the ratios for individual property in a sample of property.

To be an effective tool in measuring its appraisal performance, effective appraisal districts do not limit sales analysis to location only. Property characteristics such as class, size, age and value are also reviewed. Stratifying sales information according to property characteristics is useful in identifying lack of appraisal uniformity among property types. And, while the PVS is a good tool for appraisal planning, the timing of the study and the certification of preliminary and final taxable values are not available in time to solve current year appraisal weaknesses.

By improving ratio study methods, the CAD can ensure that necessary adjustments are made to produce values at or near the market. Effective appraisal districts conduct frequent ratio studies and perform associated appraisal maintenance, ensuring that the CAD makes the adjustments necessary to produce values at or near the market.

By not using ratio study results in a consistent manner and, most importantly, by not including all valid sales in the ratio studies, the CAD may not properly recognize and adjust schedules for market changes and may continue to appraise market areas in an inequitable manner. Furthermore, failure to use these results consistently jeopardizes the uniformity and accuracy of appraised values.

Nueces CAD, for example, has a computerized appraisal system that provides appraisal analysis through ratio studies within and among property classifications. Nueces CAD's appraisal leadership and appraisal department heads make reappraisal and value maintenance decisions based on ratio study runs within property classes, by school district and county. They conduct these ratio study runs at least quarterly to determine appraisal performance, ensuring that values are at or near the market.

RECOMMENDATION 3
Improve methods of using ratio studies to eliminate unequal levels of appraisal and make certain that all categories are being appraised at current market value.

FINDING
Bailey CAD has not updated its residential land values in more than 20 years.

In order to fully comply with Property Tax Code Section 25.02, the CAD must separate the land and improvement values for the appraisal records.

Property Tax Code Section 25.02 (a) (2), (5), (6) states:

The Appraisal of Real Estate (Appraisal Institute, 12th Edition), states that in the cost approach, the estimated market value of the land is added to the estimated cost of the structure after applying accrued depreciation to the improvement only. Potential highest and best use significantly influences land value. Therefore, the cost approach is especially persuasive when separate land values are well supported.

In the Comptroller's audit sample of property records for Muleshoe ISD, most residential land value is based on a price-per-front-foot unit value. Land that is considered "better" is appraised at $65 per front foot. All other land is appraised at $35 per front foot. The appraisal district does not document account records to indicate why a particular parcel was considered "better." The CAD makes no other distinctions, including differences for neighborhoods or paved or unpaved roads. There are no other land schedules.

Without a market-derived, detailed land schedule, the CAD cannot accurately calculate and produce the value that lot size contributes to the overall value of property, which is a necessary component used in the cost approach.

Kaufman CAD, for example, focused their reappraisal effort on improving land schedules. The Comptroller's PVS study showed improved ratios in Category D, Rural Real. By updating the land schedules, the CAD was able to appraise all categories more equitably and uniformly, improving the appraisal performance of Category A, Single-Family Residential.

RECOMMENDATION 4
Develop new detailed land and improvement schedules that track local market values for use in the CAD's automated appraisal system.

FINDING
Bailey CAD does not have local personal property schedules or a personal property manual to use when appraising business personal property.

The IAAO's Property Appraisal and Assessment Administration, 1990 Edition, is the Comptroller's official appraisal guide. This book presents a comprehensive treatment of assessment administration.

The IAAO's Property Appraisal and Assessment Administration, Chapter One, The Ad Valorem Tax System, notes that standards of practice may incorporate or be contained in laws, regulations, policy memoranda, procedural manuals and guidelines, appraisal manuals and schedules. It adds that guidelines or manuals should include repeated tasks, particularly those done by more than one person. The publication further states that there needs to be a procedure for establishing standards of practice that include updating manuals on a regular basis. Performance and progress reviews contribute to effective and efficient operations of appraisal districts. Procedures are required for monitoring the quality of appraisals, editing data and reviewing appraisals.

USPAP Standard 6: Mass Appraisal, Development and Reporting applies to all mass appraisal of real or personal property regardless of the purpose or use of such appraisals.

This standard states that a functional mass appraisal includes the following activities:

• identifying properties 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 mass appraisal results.

Bailey CAD uses rendered values as market values for personal property and does not formally verify the information or adjust the values, unless they appear to be unreasonable based on the chief appraiser's judgment. The CAD mails business personal property renditions to each business owner annually in January, although the chief appraiser indicated that not all business owners in the county submit their renditions as required by the Property Tax Code.

After review of the draft report, the chief appraiser stated:

We use Marshall and Swift, and the PTAD business personal property schedules. The PTAD don't even update their schedules for personal property. The internet is a very valuable tool and we use that more now. Things are so unique sometimes you can't have a schedule for everything.

As Marshall & Swift schedules are not geared specifically to Bailey CAD, a local modifier is necessary. The Comptroller's Field Appraiser's Guide should not be used by CADs in place of business personal property schedules. This guide is outdated and was never intended as a stand-alone manual, only as a tool for establishing local procedures.

The CAD runs the risk of producing inaccurate or inequitable values in the appraisal roll by relying on dated and inappropriate schedules and not having detailed procedures for the appraisal staff to follow.

Titus CAD, for example, developed a comprehensive plan for appraising personal property that has resulted in the CAD achieving acceptable value in this category. Titus CAD has one full time appraiser whose sole responsibility has been inspecting, analyzing renditions and performing appraisals of all personal property within the appraisal district. Additionally, the employee has been on the staff for more than 10 years and in the present position for six years. The CAD uses values rendered by the property owner and Titus CAD schedules to appraise business personal property.

RECOMMENDATION 5
Develop local schedules and a detailed appraisal manual for the appraisal of business personal property.

By failing to document the CAD's rendition process, especially the procedures used to monitor the accuracy of the values, the chief appraiser is unable to ensure the accuracy of the values.

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