Overview of County Appraisal District
County History and Demographics
According to the Handbook of Texas, Comanche County was formed by the Texas Legislature in 1856 from parts of Bosque and Coryell counties. The county comprises 944 square miles of rolling land with elevations from 650 to 1,750 feet.
Comanche County is in north central Texas and is bounded on the south by Mills County, on the west by Brown County, on the north by Eastland County and on the east by Hamilton County. Comanche, the county's largest town and the county seat, is located about 70 miles southeast of Abilene in the center of the county at the intersection of state highways 67 and 36, and 16 The county was named for the Comanche Indians that dominated the region from the 18th to the mid-19th centuries.
The county has a 238 day growing season and an average annual rainfall of 18.45 inches. The county produces a variety of agricultural products. Peanuts, pecans, grains and hay account for 40 percent of the county's $69 million annual agricultural income while beef, cattle, swine, sheep and goats account for the remainder.
The population of the county for 2003, according to the County Information Project, was 13,541 residents, with the City of Gustine having 438 residents, the City of De Leon having 2,346 residents, and the City of Comanche having 4,275 residents. The balance of the county population lives in smaller cities and towns and the rural areas.
Comanche county includes the Comanche Independent School District, De Leon Independent School District, Gustine Independent School District, and Sidney Independent School District.
Appraisal District Organization and Staffing
The appraisal district was formed in 1981 and became active in 1982. Comanche CAD has a total of seven full-time staff with one supervisory position. Two of the positions are full-time appraisers. The district contracts with Capital Appraisal Group for professional appraisal services on mineral and industrial appraisals.
Exhibit 1 outlines the district organization.
Comanche Central Appraisal District Organization
Board of Directors Gayle Graham, Chair Billy Ray Evans Royce Lesley Edith Gay Green Jerry Pyburn Sam Sparger Source: Comanche CAD.
Note: Additional information on the board can be located in Exhibit 4.
Scope of Office
The Board of Directors has no authority to set values or appraisal methods. The chief appraiser carries out the appraisal district's legal duties, hires the staff, makes the appraisals and operates the appraisal office.
The appraisal district contracts with Capital Appraisal Group (CAG) for professional appraisal services In appraising mineral and some industrial property.
The district provides appraisal services for ten taxing units, Comanche County, Comanche Independent School District, DeLeon Independent School District, Gustine Independent School District, Sidney Independent School District, City of Comanche, City of DeLeon, City of Gustine, Middle Trinity Water District, and Comanche County Consolidated Hospital District.
Exhibit 2 presents the types of properties appraised by Comanche CAD in tax year 2003. In-house staff handles all property categories except Category G (minerals), Category J (utilities), and part of Category F2/L2 (industrial - real/personal), which is appraised by CAG.
Comanche CAD Property by Category Summary with Assigned Responsibility
Tax Year 2003
Property Category Account Type Description Responsible for Appraisal Category A Residential In-house staff Category B Multi-Family In-house staff Category C Vacant Lots In-house staff Category D/E Farm/Ranch Land w/Impr. In-house staff Category F1 Commercial Real In-house staff Category L1 Commercial Personal In-house staff Category G Minerals Contracted Appraisal Firm Category J Utilities Contracted Appraisal Firm Category F2 Industrial Real In-house & Contracted Appraisal Firm Category L2 Industrial Personal Contracted Appraisal Firm Source: Comanche Central Appraisal District.
Most appraisal districts contract out some of its appraisals to contract appraisal firms. PTD does not track parcel counts appraised by external appraisers in appraisal districts. Appraisal district contracts with external appraisers routinely do not include a parcel count for the number of appraisals an external appraisal company will perform. In assessing the staff to parcel count ratio in each appraisal district, PTD uses parcel counts reported in the district's 2003 self report and the independent school districts self reports to calculate the parcels per appraisal district staff. PTD does include all of the commercial real and personal property parcels in the calculation, since PTD is unable to determine exactly how many parcels are assigned to in-house staff versus a contract appraisal firm. The total parcels appraised in-house are calculated by summing the total number of parcels reported in Categories: A, single family residential; B, multifamily residential; C, vacant lots; D, rural land; E, rural improvements; F1, commercial property; L1, personal property; M1, mobile homes; O, residential inventory; and S, special inventory, as shown in Exhibit 3.
PTD estimated that Comanche CAD staff are responsible for appraising about 18,157 parcels. The International Association of Assessing Officer (IAAO) Standards state that small taxing units run from 1,500 to 1,700 parcels per staff member and large taxing units run from 3,000 to 3,500 parcels per staff member with an average of 2,500.
Comparable districts in size to Comanche are Camp, Robertson and Lee. The number of parcels per staff member for Comanche CAD was 2,594. Camp CAD was 1,853, Robertson CAD was 1,869 and Lee was 1,295. Of course, workloads in appraisal districts may vary, sometimes drastically, due to any number of considerations other than parcel count. Geography or the size of an appraisal district may have a significant impact on the time required to work all parcels. The types of properties may also have an impact. More complex commercial and sometime even residential properties may require more staff to appraise. The data given here is meant to give the reader at least some comparison to other appraisal districts with similar parcel counts and the standards outlined by IAAO.
Exhibit 3 includes reported data concerning CAD and state and group averages.
Reported Data on Parcels, Categories Staffing, Training and Operations
Comparison to State and Group Averages
General Information Comanche State Avg. Group Avg. Parcel Size Group
(by number of locally appraised parcels)
15,000 - 19,999 Estimated # Locally Appraised Parcels 18,157 55,463 17,647 # Taxing Units 10 15 9 Locally Appraised Parcels to Staff 2,594 3,404 3,021 2003 Composition by Percentage of Value (Self Report): Residential Value 29.9% 52.6% 26.8% Non-Residential, Non Mineral 69.7% 43.6% 58.7% Non-Residential, Mineral 0.4% 3.7% 14.5% 2003 Composition by Account Category Type (Operations Survey): Real Property 15,755 45,804 17,054 Mineral Property 1,314 13,536 8,362 Business Personal Property 693 4,689 935 Individual Personal Property 328 1,342 457 Total Accounts 18,090 65,372 26,809 2003 Composition by Locally Appraised Parcel Category (Estimated from Self Report): Parcel Type # Parcels % of Parcels A 4,250 23.4% 44.1% 29.6% B 30 0.2% 1.0% 0.3% C 2,478 13.6% 13.1% 18.7% D 6,650 36.6% 24.7% 30.3% E 3,124 17.2% 4.5% 10.5% F1 646 3.6% 3.1% 3.3% L1 664 3.7% 5.7% 4.1% M1 290 1.6% 2.2% 2.5% O 0 0.0% 1.4% 0.6% S 25 0.1% 0.1% 0.0% Total 18,157 100.0% 100.0% 100.0% Financial and Staffing
Information (Operations Survey)
Comanche State Avg. Group Avg. 2003 Budget $350,880 $1,079,695 $379,748 2003 Surplus $22,380 $71,620 $26,419 2003 Surplus as % of Budget 6.4% 6.6% 7.0% 2004 Budget $350,993 $1,104,961 $390,830 % Change in Budget 0.0% $0 2.9% 2004 Budget per Total Parcel $19.33 $19.92 $22.15 Staffing Full Time 7 18 7 Part Time * 2 2 Supervisory 1 3 2 Programmers * 2 1 Supervisory to Staff Ratio 1:7 1:5 1:4 Chief Appraiser Performs Appraisals? Yes 2004 Total Compensation $38,000 $53,564 $44,059 Appraisers Full - Time 2 8 2 Part - Time * 0 2 Salary Range: Low $19,000 $24,504 $23,317 High $23,500 $37,521 $31,236 Training Budget $7,500 $8,832 $5,994 # Registered with BTPE (1) 3 9 4 Types of BTPE Certification: RPA (2) RTA (3) RTC (4) All 2 0 0 0 Operations Information
Comanche State Avg. Group Avg. Reappraisal Last Year of Reappraisal 2003 Next Year of Reappraisal * Type of Appraisal: Complete Method of Appraisal: Combination Protests 103 3,131 159 Protests per Parcel 0.6% 4.7% 0.6% Consolidated Collection No Collection Budget $0 Geographic Information System (GIS)? Yes Percent GIS Complete 85% 80% 69% Board of Directors Members 6 6 6 Tax Assessor Votes? No Elected Members 1 3 2 Note: An asterisk (*) is shown where data was not reported.
Source: Comanche CAD's and ISDs 2003 Self Reports and Comptroller 2003-2004 Appraisal District Operations Report and Comptroller comparative data for state and group averages from district self reports and the Appraisal District Operations Report.
Notes: (1) BTPE - Board of Professional Tax Examiners. (2) RPA - Registered Professional Appraiser. (3) RTA - Registered Tax Assessor-Collector. (4) RTC - Registered Texas Collector.
Self Evaluation Questionnaire
In preparation for the Appraisal Standards Review, Comanche CAD was requested to complete the IAAO's Self Evaluation Questionnaire. This instrument allows an appraisal district to assess Its compliance with acceptable procedures, standards and organization. Each district receives an electronic version of the questionnaire and the complete IAAO manual explaining each question with information on how to answer each question. Each district undergoing an appraisal standards review is requested to perform the self assessment, with the goal of assisting the district in determining how well it is performing.
Comanche County answered 110 out of 110 questions. The district's answers to the questions are included in Appendix 15.
In Chapter 1, on legal issues and assessment cycles, the district noted that because Texas does not have full disclosure on property sales it struggles with appraising all property at 100 percent of market value. It noted that it does not have resources to acquire new technologies.
In Chapter 2, on resource management, the district noted it has a reappraisal plan but does not do formal resource planning.
Chapter 3, on computerization, and Chapter 4, mapping, the district noted it has current PCs, uses paper maps and has some electronic maps, but it takes more than 30 days for it to update split properties on its maps.
In Chapter 5, data collection, the district noted it did not use hand held computers for data collection because of budget constraints. The district noted it has not had much success with surveying businesses for income information and gains most of its income information through the informal hearings process.
In Land Evaluation, Chapter 6, the district noted it confirms property sales in the area with realtors, buyers, sellers and fee appraisers. In Chapters 7, 8, and 9, on residential property valuation, commercial property valuation, and sales data, respectively, the district provided detailed responses on how it collects information and values residential and commercial property.
In Chapter 10, on personal property assessment, the district noted that in addition to receiving renditions, the district uses site inspections, the Internet, assumed name records, newspapers, sales tax information, radio, phone books and building permits to locate business personal property.
In Chapter 11, on assessment administration, the district verifies exemption eligibility using a number of methods. The district noted in Chapter 12, defense of values, that it solicits help from realtors, fee appraisers and builders on property valuations that are complex, but it felt that staffing and budget limitations made it less successful in this area.
In public relations, Chapter 13, the district does not have a public relations office, based on the size of the district. It does provide information to the public as required by statute.
Findings of the Property Value Study and Summary Worksheets
The Property Value Study (PVS) determines the total property value in each school district in the Comanche CAD. With a few notable exceptions, all CADs and the Property Tax Division (PTD) are required by law to appraise property at market value. Agricultural land and timberland are appraised according to productivity value. Market value, in short, is the price that a property would transfer from a willing seller to a willing buyer. For it to be a market transaction, neither party may be under duress to buy or sell, the sale must be on the market for a reasonable time and the parties to the sale are not related.
Local tax roll value, or local value, is determined by the CAD and submitted to PTD on its annual self-report. The PTD staff estimates the total taxable value in a school district, referred to as state value, by determining market value or by accepting the local appraised value in each property category (see Exhibit 2) in the district and then adding these category values for an overall school district value. PTD then deducts state-mandated homestead exemptions, disabled veterans' exemptions, value limitations, reinvestment zones, freeport exemptions, the loss between market value and productivity value appraisal of qualified agricultural lands, the school tax ceiling for homeowners over age 65 or disabled and other state-mandated exemptions.
PTD issues a preliminary and final PVS each year. School districts and CADs may protest the findings of the preliminary PVS through an administrative hearings process with the Comptroller, and school districts may protest the findings of the final PVS in district court. The administrative hearings process requires the protester to file a written protest with supporting documentation within 40 days of the issuance of the preliminary PVS. The PTD may amend the findings of the preliminary PVS based on the submission of the written protest, an informal hearing or a formal hearing. Formal hearings are held by a hearings examiner, appointed by the Comptroller's General Counsel, and reporting directly to the Comptroller. The hearings examiner is not an employee of the PTD.
When conducting the property value study, PTD assigns properties to various categories, such as residential, commercial and rural. Properties are divided into categories so that like properties are assessed together.
Comanche CAD appealed the findings of the preliminary study. The Independent School Districts (ISDs) did not appeal the findings of the preliminary study. Comanche CAD protested Categories A, D2/E, D1, J and F1. In Category A, the district received changes on 36 percent of the properties on which it requested changes. Staff decisions favored the district 57 percent of the time in Category C and 100 percent in Category F. The district went to a formal hearing in May 2004.
Despite the changes, the Comanche school district did not get into the confidence interval and was certified an eligible district in June 2004.
A review of the school districts in the county indicates that Comanche CAD is appraising the single-family residence properties below market value, as determined by the PTD. In the 2003 PVS, Comanche ISD fell outside the study's statistical margin of error. Single-family residences (category A), and Rural Real (category D) are the primary reasons that the school district's values are not within the acceptable range determined by the study.
There are five property categories tested in Comanche ISD: (1) category A, Single-Family Residences, making up 35.6 percent of the district's value with a weighted mean ratio of .9424; (2) category D, Rural Real, making up 28.4 percent of the district's value with a weighted mean ratio of .8728; (3) category F1, Commercial Real, making up 9.3 percent of the district's value with a weighted mean ratio of .9221; (4) category J, Utilities, making up 8.1 percent of the district's value with a weighted mean ratio of .9859; and (5) category L1, Commercial Personal, making up 6.4 percent of the district's value with a weighted mean ratio of .9902. In general, a ratio of between .95 and 1.05 in any property category makes it more likely that the district is appraising property within the margin of error, or that it is appraising property at or near market value, according to the PVS.
Comanche ISD's category A makes up 46 percent of the tested value. The appraisal district is placing a value on the category A single-family residences that is below market value by a weighted mean ratio of .9424. The primary value range of under-appraisals appear to be single-family residences above $34,000. Because this category contains almost 36 percent of the total property value in this district, the low ratio in the A category contributed to dropping the district outside the margin of error and caused the school district to be identified as eligible. The rural land and improvement values (category D) are also appraised below market value, it also is a contributing factor to the school district's values not being within the acceptable range determined by the study. Category D represents rural properties and contains two subcategories: D1 and D2. Subcategory D1, Productivity Value of Qualifying Acres, is primarily farm and ranch land that qualifies for the special productivity appraisal. Subcategory D2, Non-Qualifying Acres and Farm and Ranch Improvements, is primarily rural homes and land that does not qualify for farming, ranching or timberlands. The differences in value between qualified and non-qualified rural lands are often wide because D1 land is appraised using a special statutory method to determine the land's productivity value and D2 is based on what the land would sell for in an open market transaction. Comanche ISD's subcategory D1 makes up 23.3 percent of category D's value and 9 percent of the tested value. D1 received a weighted mean ratio of .9276. Subcategory D2, however, makes up 76.7 percent of category D's value and 28 percent of the school district's total tested value. D2 received a weighted mean ratio of .8574. This indicates that the residences in the rural areas are also being under-appraised.
A review of all the school districts in Comanche County shows that there are inconsistencies in the property values mainly with category A, Single-Family Residences. The appraisal district is placing a value on category A, Single-Family Residences, below their adjusted selling price (market value) in all of the school districts in the county.
While DeLeon ISD's category A tested below the margin of error limits, the school district was within the confidence interval limit. The single-family residences make up 41 percent of the total tested value in the school district, received a ratio of .9307, and is 30 percent of the school district's total value. In category A, the single-family residences assessed below $28,000 are under-appraised.
Gustine ISD is within the confidence interval limit. Although category A tested outside the margin of error limits with a ratio of .9086, it is only 21 percent of the school district's value. Again, in category A, the single-family residences assessed below $28,000 and were under-appraised.
Sidney ISD is within the confidence interval limit. Category A tested with a ratio of .8644, and represents only 8 percent of the school district's value. In category A, the single-family residences assessed below $25,000 are under-appraised.
In summary, the Comanche CAD needs to focus its energies on its valuation of category A, Single-Family Residence property. Although the Productivity Value of Qualifying Acres (D1) was assessed below market value in all four-school districts within Comanche CAD, the low percentage of value is not significantly affecting the study findings. The Non-Qualifying Acres and Farm and Ranch Improvements (D2), primarily rural homes, were tested in Comanche ISD at below market value.
For a statistical explanation of why the district was selected as eligible, see Appendix 18.