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Chapter 2
Findings of the Appraisal Standards Review

This chapter of the report addresses findings and recommendations from the ASR of the Harrison CAD.

Harrison CAD was formed in 1981 and became active in 1982. As of Nov. 15, 2008, Harrison CAD had 17 full-time employees; including two supervisors and seven full-time appraisers. Harrison CAD contracts with a professional appraisal services firm to appraise mineral, industrial and utility property.

The Comptroller's office asked the CAD's board of directors to complete a 21-question written survey covering board policies and procedures; chief appraiser and staff; and property appraisals. Only one board member responded and gave no negative responses to any of the questions posed in the survey.

Waskom, Hallsville, Harleton and Elysian Fields ISDs were identified as eligible ISDs in the 2003 PVS and Duval CAD received an appraisal standards review, published in 2005. The ASR made 6 recommendations, and in August 2007, PTAD published the Harrison County Appraisal District Appraisal Standards Review Follow-Up Report indicating that Duval CAD had completed the requirements of the recommendations.

Key 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 Harrison CAD's appraisal activities.

FINDING
Harrison CAD appraisal manuals do not address local issues and directives.

Property Tax Code Section 23.01(b) states the following:

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.

A detailed appraisal manual can assist a CAD in adhering to codes and standards.

Harrison CAD's Appraisal Procedures Manual was written in 2007 and is updated as needed. The chief appraiser stated that it serves as the appraisal manual.

The manual does not contain detailed procedures for completing an appraisal. Information is difficult to locate even with the assistance of the table of contents. The reviewer examined 13 properties in the Elysian Fields ISD with the assistance of CAD staff. Due to the reviewer's familiarly with appraisal schedules and procedures, he was able to recreate most of the appraised values using CAD schedules, but there were instances in which this process was not possible. An inexperienced appraiser would have a difficult time using the current Harrison CAD appraisal guidelines to perform appraisals. The reviewer could not reproduce the CAD's values using the existing procedures.

Staff appraisers are responsible for specific areas in each of the market areas, primarily defined as ISDs. According to appraisal staff, an appraiser does fieldwork individually. Upon completion of fieldwork, each appraiser enters data into the appraisal system. This data is reviewed by the administrative assistant for accuracy.

Residential properties are appraised using market-based schedules. No section in the manual addresses residential properties and it does not contain photographic examples of different residential classifications to aid in consistency.

Market based schedules are used to appraise both vacant land and improved property. The manual has no instructions for valuing land or sites. It includes a table for land adjustments, but no directions for using them.

Commercial properties are appraised using Marshall & Swift commercial schedules with locally developed modifiers. The CAD's lack of sales data makes the development of local modifiers difficult.

A staff appraiser handles personal property appraisals. According to the chief appraiser, the percentage of renditions received has increased over the past few years. A 10 percent penalty is assessed to accounts which fail to render personal property values. Staff does not use trending-analysis on personal property.

No depreciation tables were provided, and CAD staff members reported that depreciation is calculated by appraiser estimations. It appears that depreciation is assigned in an arbitrary manner. Without a depreciation schedule, properties in similar condition could be assigned different levels of depreciation leading to unequal appraisal.

The chief appraiser made the following statements after reviewing the draft ASR:

• HCAD does not allot appraisal assignments to inexperienced appraisers. Inexperienced appraisers always work with and are trained by experienced appraisers. The existing manual is designed to mirror the State Property Tax Code and information is located the same way as the code book.
• HCAD uses Marshall & Swift Valuation information to aid in classifying residential properties.
• HCAD employs two personal property appraisers.
• HCAD does not assign inexperienced appraisers to work alone. Therefore an inexperienced appraiser would not rely on an appraisal manual that is used as a guide only. A guide can not be expected to encompass all possible scenarios encountered in the appraisal process.
• HCAD does have and are actively using depreciation tables. The effect of deferred maintenance, functional and economic obsolescence is applied by the appraiser.
• HCAD will expand the current appraisal manual to provide detailed instructions for completing appraisal assignments.

With several appraisers working in a mass appraisal environment, the importance of consistent data is critical. Appraisal manuals require detailed explanations of procedures, detailed descriptions of class differences, photographic examples, valuation schedules and depreciation schedules. Appraisal manuals can assist officials in training new employees, evaluating existing appraisers and assisting the public in understanding the appraisal process.

Kaufman CAD has appraisal procedure manuals which describe field procedures, processing of cards, reviewing sales data and appeals procedures. It uses a residential classification guide with photos and descriptions in conjunction with the appraisal manual.

RECOMMENDATION 1
Update the appraisal procedures manual to provide detailed instructions for completing appraisal assignments.

FINDING
Harrison CAD's annual appraisal maintenance has been insufficient to address valuation issues in a changing market as required by Property Tax Code Section 23.01.

Property Tax Code Section 23.01 states the following:

The 2003 ASR of Harrison CAD recommends the CAD use ratio studies to make effective reappraisal decisions and use the results in the appraisal process. During the follow-up review, the previous chief appraiser indicated that he used ratio studies to make decisions and that the invalid findings in 2003 were due to a decision by him and the board not to use the information because they expected a decline in property values for the following year.

Based on 2006-07 PVS results and supported by the CAD's 2008 ratio studies, Category D properties are underappraised (Exhibit 1).

Exhibit 1
Harrison CAD
Category D 2006-07 PVS and 2008 CAD Ratio Study Results

ISD	2006 PVS Ratio	2007 PVS Ratio	2008 CAD Ratio Study (# Sales)
Karnack	0.8859	0.8557	0.8160 (5)
Marshall	0.8267	1.0176	0.9072 (38)
Waskom	0.8843	0.7545	0.9690 (2)
Hallsville	0.8074	0.8210	0.8674 (31)
Harleton	0.7917	0.9470	0.8742 (6)
Elysian Fields	0.8402	0.7331	0.9029 (4)

Source: Texas Comptroller of Public Accounts, 2006-07 PVS and 2008 Harrison CAD's ratio study.

A good ratio study allows a CAD to identify market areas and changes within them. The 2007 PVS indicated the CAD is undervaluing Category D property in all but one ISD. The CAD's invalid finding in Elysian Fields ISD in the 2007 PVS was partially due to not recognizing market changes in Category D properties and not making necessary adjustments to reflect those changes. CAD staff indicated that land schedules for 2007-08 were increased.

The CAD provided documents that it identified as ratio studies for 2006-07; however, the documents are a list of sales that cannot be sorted into categories, market areas or stratified by value. The copies are of documents from the previous chief appraiser and are not entered in the appraisal software system. While the documents indicate an effort to gather sales data, the information is not useful in this format. The 2008 ratio study can be stratified by type of property and by location, which was generated by the CAD from the appraisal system. Using this format is more helpful than the format of the 2006-07 studies. The CAD plans to use the ratio study in future reappraisals.

CADs use ratio studies to help plan appraisal maintenance programs. Ratio study results can indicate property categories in the CAD where values no longer reflect the market. If a ratio study shows appraised values do not reflect market, the CAD analyzes available sales to determine the market adjustment factor. The market adjustment factor is the percentage that the CAD uses to adjust appraisal schedules for use in determining market value.

After reviewing the draft ASR, the chief appraiser stated, "The new chief appraiser evaluates ratio study findings to adjust appraisal results to market value. HCAD has complied with this recommendation." The appraisal district provided no supporting documentation for these statements.

Brown CAD, for example, has software technology for ratio studies that is adequate for its needs, and the frequency with which ratio studies are used meet IAAO appraisal procedures and standards. The automated appraisal system produces ratio studies on demand; staff need only input the property sales information and identify the area for study. The CAD adjusts sales used in valuation analyses to the valuation date of January 1 and uses resale to calculate and justify modifiers for neighborhoods or subdivisions and, on occasion, property types. This type of analysis is useful as a defense for value increases on properties that have not sold. Brown CAD groups residential property by neighborhoods. Staff conducts an annual ratio study at each appraisal season's end to see if it needs to make schedule changes, location modifiers or other changes. The CAD conducts additional ratio studies following change implementation.

RECOMMENDATION 2
Evaluate ratio study findings to adjust appraisal results to market value.

FINDING
Harrison CAD does not have agriculture valuation guidelines and does not adequately update the agricultural productivity schedules associated with Subcategory D1 property.

The Comptroller's Manual for the Appraisal of Agriculture Land states that the CAD do the following:

• create a land classification system covering each type of agricultural land typical in the district:
• calculate typical net income, based on a variety of sources, for prudently managing agriculture operations;
• determine land uses and degree of intensity standards for qualifying land;
• provide application and act separately on each agricultural application;
• determine if and when a change of use occurs and sends notice of the determination to the property owner;
• appraise each property and prepare appraisal records listing information on agricultural property; and
• notify the property owner of the appraisal districts actions of the Property Tax Code requires it.

Property Tax Code Section 23.51(4) states the following:

(4) "Net to land" means the average annual net income derived from the use of open-space land that would have been earned from the land during the five-year period preceding the year before the appraisal by an owner using ordinary prudence in the management of the land and the farm crops or livestock produced or supported on the land and, in addition, any income received from hunting or recreational leases. The chief appraiser shall calculate net to land by considering the income that would be due to the owner of the land under cash lease, share lease, or whatever lease arrangement is typical in that area for that category of land, and all expenses directly attributable to the agricultural use of the land by the owner shall be subtracted from this owner income and the results shall be used in income capitalization. In calculating net to land, a reasonable deduction shall be made for any depletion that occurs of underground water used in the agricultural operation. For land that qualifies under Subdivision (7) for appraisal under this subchapter, the chief appraiser may not consider in the calculation of net to land the income that would be due to the owner under a hunting or recreational lease of the land.

Exhibit 2 shows the 2006-07 PVS results for Harrison CAD's productivity values.

Exhibit 2
Harrison CAD
2006-07 CAD Productivity and PTAD Values/Acres

Pasture type	CAD 2006 Reported Values $/Acre	PTAD 2006 Values $/Acres	CAD 2007 Reported Value $/Acre	PTAD 2007 Values $/Acres
Improved	$58.40	$84.30	$65.98	$90.72
Native	$50.35	$79.20	$55.88	$89.34

Source: Texas Comptroller of Public Accounts, 2006-07 PVS.

PVS results show the CAD is undervaluing Subcategory D1. The chief appraiser stated that the CAD obtains acreage values from PTAD and does not perform calculations with local income data, in violation of Property Tax Code Section 23.51(4). Though Harrison CAD stated it uses values supplied by PTAD, the CAD's 2007 values differ from PTAD values for that period.

Harrison CAD values land at a lesser price-per-acre compared to adjoining counties (Exhibit 3).

The Texas Chapter of the American Society of Farm Managers and Rural Appraisers provides annual general market conditions for all regions of Texas . Harrison County is in Region 4 and grouped into the Piney Woods North area with Anderson, Cherokee, Gregg, Houston, Nacogdoches, Panola, Rusk, Shelby and Smith counties. This information is available on the Texas A&M Real Estate Center Web site. The Texas Rural Land Value Trends 2007 describes this area as continuing to be a dynamic land market. The report states: "The Piney Woods North land market remained active through most of 2007, with prices increasing. Large pasture tracts, which sold in late 2005, re-sold in 2007 for an approximate 10 percent to 20 percent increase. Again, brokers report a lack of listings of good properties and that sellers have high price expectations."

Exhibit 3 indicates Harrison CAD's productivity values are low compared to surrounding CADs. Continuing to estimate the productivity values based on data which is not reflected with the local market, can generate invalid findings.

Exhibit 3
Harrison CAD Comparison to Surrounding CADs
Subcategory D1 Productivity Values, 2007 PVS

CAD Reported Improved Pasture

CAD	Value $/Acre
Gregg	$155.03
Shelby	Not available
Panola	$112.01
Harrison	$65.48
Anderson	$110.01
Cherokee	$95.07
Henderson	$120.01
Houston	$81.14
Nacogdoches	Not available
Rusk	$105.59
Smith	$126.18

CAD Reported Native Pasture

CAD	Value $/Acre
Gregg	$88.84
Shelby	$70.25
Panola	$69.03
Harrison	$55.88
Anderson	$97.72
Cherokee	$95.00
Henderson	$69.99
Houston	$80.01
Nacogdoches	$101.22
Rusk	$65.97
Smith	$222.82

Source: Texas Comptroller of Public Accounts, 2007 PVS.

After review of the draft ASR, the chief appraiser stated, "HCAD will develop local agricultural valuation guidelines and procedures; update and maintain schedule and income data (when available) to reflect current market conditions."

Erath CAD, for example, has written guidelines for administering special-use evaluations, specifically for administering Subcategory D1 property. Written agricultural guidelines provide consistency in administration and help eliminate subjectivity in the decision-making process. Clearly defining what is typical for the area and what activities meet the degree of intensity requirements greatly assist CAD staff and the general public in understanding the local market.

RECOMMENDATION 3
Develop local agriculture valuation guidelines and procedures and update and maintain agricultural productivity schedules and income data to reflect current agriculture market conditions.

FINDING
Harrison CAD does not have an agricultural appraisal advisory board (Ag board).

Property Tax Code Section 6.12 states the following:

The Texas Legislature authorized Ag boards to assist chief appraisers in appraising agricultural and timber land.

A CAD staff appraiser appraises the CAD's open-space land. Since the CAD does not have an Ag board, it does not receive local input when valuating agricultural and timber land. Elysian Fields ISD received an invalid finding due in part to low agricultural and timber land use values.

An Ag board is not available to assist the CAD in gathering sets of leases typical for the area, determining typical expenses in the area or assisting with any other agriculture and timber land appraisal-related issues. The additional expertise could be helpful in allowing the CAD to gather recent income and expense data for the productivity valuation process on agricultural or timber land properties. The CAD then can use this data to determine productivity values for Subcategory D1 properties.

The lack of an Ag board can hinder the CAD from gathering local income and expense data. Continuing to operate without the assistance of an Ag board can continue to achieve low agriculture and timber land values.

After review of the draft ASR, the chief appraiser stated, "The chief appraiser will discuss with the board of directors the subject of appointing an agricultural appraisal advisory board."

RECOMMENDATION 4
Appoint an agriculture appraisal advisory board to assist the CAD in establishing productivity values for agricultural land.

FINDING
Harrison CAD's appraisal cards do not comply with Comptroller's Property Tax Rule 9.3001 and lack critical information on reappraisal activities.

Comptroller's Property Tax Rule 9.3001 states the following:

Harrison CAD's chief appraiser reported that reappraisals occur at least once every three years as required by law. The section of the appraisal cards which indicates the date of the last appraisal and the appraiser's initials are not in compliance. Based on the sample used in this review, most of the cards show an appraisal date of Jan. 1, 1999, and a checked date of Jan. 1, 2000, with no appraiser initials. This violates Comptroller Rule 9.3001(c)(3).

The section of the appraisal card that indicates when the parcel was last appraised is used to verify data. Some parcels appeared to have been reappraised, but the information in this section remained unchanged.

Exhibit 4 shows a sampling of appraisal cards without specific reappraisal data.

Exhibit 4
Sampling of Appraisal Cards
Texas Comptroller Rule 9.3001(c)(3) Data

Parcel #	Appraised by	Appraisal Date	Checked By	Checked Date
R010087571	None	1/1/00	None	1/1/00
R010085319	None	1/1/99	None	1/1/00
R000045704	DM SD	1/1/99	DM SD	9/21/06
R000047597	None	1/1/99	None	1/1/00
R000045640	None	1/1/99	None	1/1/00
R000052196	None	1/1/99	None	1/1/00
R000023941	None	1/1/99	None	1/1/00
R000022690	None	1/1/99	None	1/1/00
R000071517	None	1/1/99	None	1/1/00
R000035344	None	9/4/04	DM SD	9/19/06
R000075148	SD DM	9/5/06	None	1/1/00

Source: Harrison CAD's appraisal cards, November 2008.

This section of the appraisal card indicates when a parcel was last inspected and by whom. Most of the cards show no notations in the appraised-by or checked-by fields. Those with notations were the initials of the staff member who did the appraisal and reviewing. Failure to update the system that prints the appraisal cards leads to further inefficiencies. CAD staff manually pulls the appraisal files to determine when a parcel was last appraised or reviewed, leading to further inefficiencies.

After review of the draft ASR, the chief appraiser stated, "The new chief appraiser has ensured that appraisal cards are in compliance with Comptroller Property Tax Rule 9.3001. HCAD has complied with this recommendation."

RECOMMENDATION 5
Ensure all appraisal cards comply with Comptroller Rule 9.3001.

FINDING
Harrison CAD's mapping system does not comply with Comptroller Rule 9.3002

Comptroller Property Tax Rules 9.3002 addresses mapping as follows:

The 2003 ASR included a recommendation that the CAD develop a plan and systematically replace the old computer system, move data to the newly installed system and integrate it with the current mapping system. This computer system was completed in 2004, but as of November 2006, only an estimated 35-40 percent of the maps were completed. The chief appraiser estimated that all the maps would be complete by end of 2009.

The CAD states its mapping system is approximately 70 percent complete. The CAD contracted with a third-party in 2005 to assist in completing the mapping process; however, most of the mapping work is performed in-house. CAD staff indicated that the entire mapping system should be complete in five to seven years.

Harrison CAD cannot identify all county parcels on the mapping system. Some parcels have not been mapped on the system. Mapping is a basic function in the appraisal process. A completed mapping system can help staff ensure all property is located and valued in a fair and equitable manner. Without a complete set of maps, the CAD's job of successfully completing reappraisal schedules could be hampered. The completed mapping appears to assist the appraisal staff in locating property.

Exhibit 5 shows how the CAD's maps are not in compliance with Comptroller Rule 9.3002

Exhibit 5
Harrison CAD
Compliance with Rule 9.3002 on Tax Maps

Comptroller Rule 9.3002 Mapping Requirement	Description of CAD's Level of Compliance with Specific Sections of Rule 9.3002
Does the CAD draw its tax map system to scale and delineate lot and property lines with dimensions or areas and identifying numbers, letters or names for all delineated lots or parcels?	CAD maps are drawn to scale and delineate lots and property lines. There are no dimensions, parcel numbers or street or road names on several of these maps. After review of the draft ASR, the chief appraiser stated, "These items are on the completed portion of the mapping system."
Does the CAD divide the tax map into sections drawn at a scale large enough to serve the purposes of property assessment? [Note: The CAD can draw developed or subdivided areas at a different scale than undeveloped or unsubdivided tracts.]	Completed maps are drawn to a scale large enough to use in the assessment process.
Does the CAD tax map assign each section and each parcel numbers in accordance with a parcel identification numbering system?	The parcel indentification system does not appear to be assigned to the maps in a consistant manner. After review of the draft ASR, the chief appraiser stated, "Parcel identification numbers are assigned within surveys as mapped on a consistent basis."
Does the CAD record these numbers on the tax map, section and parcel?	No. After review of the draft ASR, the chief appraiser stated, "Yes. Parcel identification numbers are recorded on the maps so the properties may be properly identified."
Does the CAD also record the identifying number for each parcel as recorded on the tax map on the appraisal card maintained for that parcel?	Not noted. After review of the draft ASR, the chief appraiser stated, "Yes."
Does the CAD annually update the tax map system to incorporate any new subdivisions or property transfers as indicated by the filing of subdivision plats or deeds with the county clerk's office?	No. After review of the draft ASR, the chief appraiser stated, "Yes. As plats or deeds are received, the mapping system is updated at that time to maintain current maps. This is an ongoing process, not an annual process."
Does the CAD maintain information required by Rule 9.3002 in electronic data processing records rather than physical document? If yes, please describe. If no, provide CAD's reason for not doing so.	According to chief appraiser, the mapping system is saved twice a week. After review of the draft ASR, the chief appraiser stated, "The mapping system is backed up daily."

Source: Harrison CAD maps.

Five to seven years is a long timeframe for converting mapping systems. Delays hamper the CAD's ability to appraise property. Supplying site dimensions gathered in the mapping process and incorporating them with the appraisal system allows the appraisal staff to better assess land and site values.

After review of the draft ASR, the chief appraiser made the following statements:

• The mapping system is now 81 percent complete. A lengthy completion time was given due to the fact the majority of parcels remaining to be mapped must be abstracted. Abstracting these properties is a tedious, time consuming task. It is not a simple matter of mapping a current deed.
• As previously stated, the mapping system is currently incomplete; however HCAD staff is working diligently toward completion.
• The majority of the mapping system to be completed are properties that must be abstracted. This is an extremely time consuming task and to determine an exact timeline for completion is not feasible.
• HCAD is currently devoting all available resources to the development of the mapping system.

Johnson CAD, for example, maintains a multipurpose graphic system integrated with mapping technology, is actively involved in multipurpose geographic information systems and works with local governments, the county engineer, the 9-1-1 coordinator and the sheriff's department to eliminate duplication and minimize costs.

RECOMMENDATION 6
Develop a timeline and devote necessary resources to develop maps that comply with Comptroller Rule 9.3002 within one year from the date of this report's publication.

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