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Chapter 2:
Findings of the Appraisal Standards Review

In December 2005, the Comptroller released an ASR of Starr CAD because the 2003 PVS identified Roma ISD as an eligible school district. Within Roma ISD, single-family residential properties sampled contributed to the overall finding of invalid value, with a weighted mean ratio of .9219.

The report made 12 recommendations to improve Starr CAD's appraisal practices and operations. At the time of the review, the challenges facing Starr CAD included the lack of formal appraisal procedures and lack of documentation in most areas of operations, including the reappraisal of property on a timely basis.

PTAD reviewed documentation submitted by Starr CAD in December 2006 and conducted a follow-up, on-site visit to assess its progress in implementing the report's recommendations. Starr CAD completed six of the 12 recommendations; it made considerable progress on four other recommendations, but it had not implemented two recommendations.

The CAD's 2004 and 2005 reappraisal efforts produced positive results, as all three of the CAD's school districts received local value in the final 2004 and 2005 Property Value Studies. However, the 2006 PVS shows invalid local values for Rio Grande City and Roma ISDs.

The CAD continues to face some of the same challenges that prompted 2003's ASR. With two school districts now eligible, the situation appears exacerbated. The CAD's board of directors must remain cognizant of Property Tax Code Section 5.102(d) that requires that if the appraisal district fails to comply with the recommendations in the report, the Comptroller must notify the district judge of this failure. The judge(s) must then appoint a five-member board of conservators to supervise the operations of the appraisal district until the Comptroller's office determines that the taxable value of each school district for which the appraisal district appraises property is the local value for the school district.

This chapter of the report addresses commendations, findings and recommendations from the ASR of Starr CAD in three sections:

2.1
Commendable Practice

As part of its review process, PTAD identified a best practice used by Starr CAD. This commendable practice can improve efficiency or address past operational weaknesses and may give other appraisal districts ideas for improving operations.

FINDING
Starr CAD moved from an office with limited space and parking into a newly constructed office building with adequate space for operations and sufficient public parking.

Property Tax Code Section 6 authorizes a CAD's board of directors to purchase or lease real property or construct improvements necessary to establish an appraisal office.

Starr CAD's offices were located near the downtown area of Rio Grande City in a converted corner store with very limited space for staff and records. Parking was limited to a few parking spaces in front of and to the side of the building. Parking was so restricted that, during busy periods of the year, taxpayers might not find parking.

The new Starr CAD office is a separate, stand-alone building on the street in front of a new shopping mall parking lot. During most of the year, there are sufficient parking spaces in front of the CAD's building for taxpayer visits. During the busier tax appeal periods, there is ample additional parking in the shopping mall parking area.

By moving to the new location, Starr CAD provides offices for appraisers to permit taxpayers to speak confidentially to the appraisal staff. It also provides a new area for taxpayers to make filings and for staff to store historical property records. Public and taxpayer areas are well designed and comfortable.

Except for the reception area and the mapping section, the non-public areas require a security code for access. This protects staff from unwarranted intrusions.

By moving to a new, stand-alone office building with plenty of space and parking, the board of directors exhibited foresight and consideration to staff and taxpayers. The building includes sufficient space for additional staff as the county population and number of real personal property accounts grows.

COMMENDATION
The board of directors leased land and constructed a new office building to meet the CAD's current and future needs.

2.2
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 Starr CAD's appraisal activities.

FINDING
Starr CAD uses the cost approach as the principal appraisal method to appraise single-family residential properties, instead of the sales comparison approach, considered by the IAAO's Standard on Mass Appraisal Section 4.6 as "the best approach for single-family residential property."

Property Tax Code Section 23.0101, states:

In determining the market value of property, the chief appraiser shall consider the cost, income, and market data comparison methods of appraisal and use the most appropriate method. (Emphasis added.)

The "market data comparison method" is another name for the sales comparison approach. While the IAAO Standard on Mass Appraisal considers the cost approach a "good supplemental approach" that can "serve as the primary approach when the sales data available are inadequate," the sales comparison approach is the preferred method for single-family residential property because sales are considered the best evidence of market value. Typically, in valuing single-family residential property, the cost approach is more reliable for properties in newer subdivisions.

As shown in Exhibit 1, Starr CAD is valuing single-family residential properties below the PVS confidence interval across all school districts tested in the PVS in its jurisdiction.

Exhibit 1

Starr CAD: Single-Family Residential Property Ratios
Rio Grande City and Roma ISDs
2005-07 PVSs

School District	2005 PVS Ratio	2006 PVS Ratio	2007 PVS Ratio
Rio Grande City ISD Single-Family Residential Properties	0.9650	0.8151	0.7906
Roma ISD Single-Family Residential Properties	0.9687	0.7268	0.6681

Source: Texas Comptroller of Public Accounts 2005 PVS, 2006 PVS and 2007 PVS.

As the exhibit shows, the values show a decreasing trend.

Starr CAD's appraisers do not analyze market conditions to calibrate – or adjust – cost approach value estimates and update land and building schedules.

Starr CAD's chief appraiser is responsible for market analysis and development of the CAD's land and building cost tables. The CAD relies on its appraisal software vendor to update its cost tables based on the chief appraiser's requested changes.

Starr CAD's computer assisted mass appraisal (CAMA) system is limited to only one valuation approach, a very basic cost approach. The CAMA system is missing program modules for income and sales comparison approaches. Thus, Starr CAD appraisers cannot consider the three approaches to value when appraising property.

When an appraisal district registers low ratios throughout its jurisdiction, as is the case with Starr CAD, it points to a problem with either its land or building schedules. Exhibit 2 shows that vacant land ratios in Starr CAD are below the acceptable confidence interval in the PVS, suggesting the CAD's land schedules are not working as intended.

Exhibit 2

Starr CAD: Vacant Land PVS Ratios
2005, 2006 and 2007

Vacant Lot PVS Ratios by Stratum	2005	2006	2007
Rio Grande City ISD Stratum 1	0.8465	0.7010	0.5147
Rio Grande City ISD Stratum 2	0.8708	0.6267	0.7761
Rio Grande City ISD Stratum 3	1.0028	0.7910	0.9391
Rio Grande City ISD Stratum 4	1.3652	1.0440	0.5860
Roma ISD Stratum 1	0.9392	0.7456	0.5973
Roma ISD Stratum 2	0.9842	0.6668	0.8265
Roma ISD Stratum 3	0.9888	0.6457	0.9937
Roma ISD Stratum 4	1.0198	0.8384	1.0647

Source: Texas Comptroller 2005, 2006 and 2007 PVS.

Generally, ratios are in a decline in all strata. In 2005, Roma ISD vacant land ratios were within the acceptable confidence interval in all but one stratum. In 2006, all strata had ratios below acceptable levels and in 2007, only one stratum had an acceptable ratio. In 2005 and 2006, Rio Grande City ISD had one stratum in each year within the acceptable confidence interval, but none in 2007.

Out of more than 11,000 vacant lot accounts, the CAD adjusted only 85 in 2006 and 58 in 2007 (Exhibit 3).

Exhibit 3

Starr CAD: Number of Vacant Land Accounts Adjusted
2006 and 2007

Vacant Lot Accounts in 2005	2006 Rio Grande City ISD	2007 Rio Grande City ISD	2006 Roma ISD	2007 Roma ISD
Accounts not changed	6,829	6,818	4,123	4,111
Accounts removed	210	237	33	56
Accounts increased	19	5	12	9
Accounts decreased	26	24	28	20
Total accounts changed	45	29	40	29

Source: Starr CAD Electronic Appraisal Records Submission (EARS) reports, 2006 and 2007.

As Exhibit 4 demonstrates, the PVS found sales in both school districts, which the CAD could use in a sales comparison approach, or it could use them to fine-tune its cost approach.

Exhibit 4

Starr CAD: Number of PVS Sales Samples for Single-Family Residential Properties
Rio Grande City and Roma ISDs
2005-07 PVS

School District	2005 Final PVS Sales	2006 Final PVS Sales	2007 Final PVS Sales
Rio Grande City ISD Single-Family Residential Sales	29	36	32
Roma ISD Single-Family Residential Sales	9	16	8
Total Single-Family Residential Sales	38	52	40

Source: Texas Comptroller of Public Accounts 2005 PVS, 2006 PVS and 2007 PVS.

Property Appraisal and Assessment Administration, the appraisal manual approved by the Comptroller, points out that, if necessary, the appraisal district can select sales for comparison for up to five years. When real estate markets are stable, no time-adjustments are necessary. If the market shows either inflationary or deflationary influences, then the CAD must make the adjustments indicated.

Reliance on the cost approach, instead of the preferred sales comparison method, has contributed to Starr CAD valuing single-family property inaccurately in the 2006 PVS. The 2007 PVS showed the same results. This contributes to an inequitable distribution of the tax burden on property owners. By using the sales comparison approach to value single-family residential property, Starr CAD can ensure that it treats all taxpayers equally and fairly and that its member school districts receive property values that assure continued state education funding at equitable levels. Moreover, the CAD would come into compliance with the statutory benchmark for using the most appropriate alternate appraisal method.

By not considering appraisal approaches other than cost, Starr CAD cannot identify limitations between approaches or needed updates to cost tables. Additionally, failure to perform a market analysis can result in unreliable ratio studies results.

IAAO's Property Appraisal and Assessment Administration, Chapter 6 identifies several methods to adjust cost tables. One approach, the hybrid model, contains the standard land and building elements from the cost approach. A CAD can calibrate the hybrid model directly against market sales transactions to provide it with a direct market analysis that it can convert into the cost approach.

According to the IAAO's Standard on Automated Valuation Models, an appraisal office should calibrate its appraisal approach directly against sales. After specifying its appraisal approach, the CAD:

• tests the approach with calibration;
• adjusts it to the appraisal approach;
• tests again with calibration; and
• repeats this process until it achieves statistically significant improvement.

IAAO points out, in its Standard on Mass Appraisal Section 4.3, that "when sufficient valid sales are available, [the sales comparison] approach tends to be the preferred valuation method." To achieve the best results, the CAD must estimate:

...the value of a subject property by analyzing the sales prices of similar properties. Mass appraisal programs should be able to adjust sales prices for date of sale. Adjustments should be considered for financing, personal property, assumed leases, delinquent taxes, and special assessments. Sales with special conditions, such as trades, exchanges, partial interests, land contracts, and auctions require a thorough validation and may be used with caution. ...Reliability of the sales comparison approach rests on the number and quality of available sales.

RECOMMENDATION 1
Use sales to develop land and building schedules that reflect local market values.

FINDING
Starr CAD does not fully document its appraisal processes in appraisal manuals.

The 2003 ASR recommended that the CAD develop an appraisal manual that included comprehensive instructions on how to perform an appraisal for typical Starr County property. The assistant chief appraiser developed a seven-page manual that addresses appraiser interaction with property owners and the preparation of paperwork, but it does not provide instructions on how to perform appraisals or guidelines for using sales and ratio studies. The manual does not provide instructions on how to use the appraisal methods described in the reappraisal plan or how to update relevant property characteristics. The assistant chief appraiser is aware of the need to provide this additional information but indicated the CAD does not have sufficient sales.

The assistant chief appraiser also provided copies of schedules used by the appraisers in the field, some of which the CAD last updated in 1995. But there are no guidelines or instructions on their use.

The CAD's manual does not have property descriptions, an explanation of quality construction classification, descriptions and explanations of condition variables, descriptions to determine building year built, effective year built, building ages or depreciation schedules.

A review of the CAD's real property appraisal manual shows the following:

• rural land unit values are not included in the CAD's land schedules;
• some land class codes are not in land schedules;
• instructions for application of land unit price values are missing;
• corner lots are adjusted by 120 percent, but there are no land adjustment schedules in the manual;
• neighborhoods and neighborhood percentage adjustments are missing;
• depreciation tables are missing; and
• documentation of valuation approaches is missing.

Starr CAD modeled its business personal property manual around the first paragraphs of USPAP's Standard Rules 7, 8, 9 and 10. In the personal property manual, the narrative under Standard Rule 9 repeats much of Standard Rule 7. USPAP Standard Rule 10 repeats some sections of Standard Rule 8.

Without written definitions, descriptions, sample pictures and instructions on use of the appraisal manual, appraisers can incorrectly apply valuation approaches or make inaccurate and inconsistent judgments about property values. By developing and using functional appraisal manuals, Starr CAD can provide its appraisers with guidelines for consistent application of valuation methods and formulas and enable appraisers to adequately develop, document and report USPAP-compliant mass appraisals.

According to IAAO's textbook, Property Appraisal and Assessment Administration, Chapter One, The Ad Valorem Tax System, an appraisal office should describe repeated tasks, particularly those done by more than one person, in procedures guidelines available to all staff. These can include the following:

• manuals that establish work procedures;
• procedures that promote uniformity of approach to tasks;
• policy memoranda that set performance goals; and
• forms that promote uniformity.

RECOMMENDATION 2
Rewrite the appraisal manual to eliminate duplication and expand directions and examples.

The CAD should also implement a schedule for reviewing and updating the manual on a regular basis.

The follow-up report to the previous ASR suggested the CAD consult with other appraisal districts for guidance in this area.

FINDING
Starr CAD does not have a complete discovery procedures manual, causing information to be missing from property records.

IAAO Standard on Mass Appraisal of Real Property Section 3.3 states, "The assessor should collect and maintain sufficient property characteristics data for classification, valuation, and other purposes. Accurate valuation of real property by any method requires descriptions of land and building characteristics." Property characteristics should be based on the following:

• factors influencing the local market;
• requirements of the valuation method;
• the CAD uses of classifications;
• property tax policy; and
• benefits and costs.

To discover real properties, Starr CAD uses deed transfers from the county clerk's office; building permits from the cities of Rio Grande City and Roma; subdivision plats; and septic tank, water and electricity lists. A multiple listing service does not exist in Starr County. The few realtors and developers in Starr County share publicly known real estate information with the CAD.

A review of Starr CAD's appraisal records from the ASR audit sample shows the following:

• most property record cards do not have situs or a street address;
• some records have land site values with no corresponding land characteristics, such as size;
• the CAD is not delineating neighborhoods nor using neighborhood percentage adjustments;
• known flood plains are not noted on the property records;
• known legal title problems are not noted on the property records;
• most property record cards are missing year built and effective year built;
• corner lots are not identified on the property records;
• some property records are building-only records without referring back and tying them to related land property records; and
• property records have no sketches or pictures.

Starr CAD's property records show a concentration of the property characteristics needed to generate an assessment roll with less regard for the characteristics used to develop property values. The CAD's manager and professional appraisal staff were unaware of the missing property characteristics such as condition, year built and effective year built. The appraisers generally indicated that the information was on the old property records, but they had not transferred it to the CAMA system. They did not provide copies of the old records, however.

When standard information is missing from the property records and CAMA system, appraisers incorrectly apply valuation approaches or make inaccurate and inconsistent judgments about property values. This leads to incorrect application of judgment values such as percent good, which generates incorrect building values. By developing comprehensive discovery manuals and accurately recoding value-related property information in the CAMA system, Starr CAD will provide its appraisers consistency in the application of valuation formulas.

Brown CAD, for example, has continuous data gathering procedures that conform to IAAO and USPAP standards and contribute to effective assessment of property.

RECOMMENDATION 3
Prepare a written discovery procedure manual and use it to gather detailed data for all property.

FINDING
Starr CAD lacks written procedures for gathering sales price data and verifying sales with sellers, buyers or real estate brokers.

According to IAAO's textbook, Property Appraisal and Assessment Administration, Chapter 5, Data Collection and Management, "Sales data must be collected, edited and adjusted to obtain valid indicators of market value."

The IAAO text recommends collecting the following sales data whenever available:

• sales price, the single most important information about any sale;
• names and addresses of buyers and sellers, which allows appraiser to contact for additional information on the sale;
• relationship of buyer and seller, which helps distinguish an arms-length transaction;
• property address, parcel identifier, legal description and instrument number, which links sales to CAD records;
• type of transfer and deed, which also helps identify an arms-length transfer;
• interest transferred, or what property rights are included in the sale;
• personal property value, the price of which needs to be deducted from the sales price;
• financing, the terms of which can affect sale price and require adjustments; and
• date of transfer, which is needed for determining time-of-sale adjustments.

Three basic sources of sales data are deeds, contracts or agreements of sale and affidavits of property value. When this information is unavailable, incomplete or requires verification, a CAD can obtain sales information from buyers and sellers by mail questionnaire, telephone inquiry or face-to-face interviews. As a final resource, real estate agents, title companies, private appraisers, leasing agents and certified property managers are good sources of information.

Starr CAD's previous ASR recommended that it establish written procedures for gathering and analyzing sales. The CAD claims it does not have access to sales information, and thus did not develop written procedures for gathering and analyzing sales data. The CAD's informal process includes sending out an annual sales survey to buyers and making telephone calls to developers for the value of lots. The CAD also talks to a local contractor regarding changes in ownership and improvements. The deputy chief appraiser describes the CAD's process as follows:

• receive daily electronic sales transactions from deeds from county clerk;
• load sales into CAMA system;
• separate sales property characteristics file as of sales date;
• mail sales questionnaires to buyers;
• make follow-up calls to non-responsive buyers; and
• adjust land schedules with sale information.

Written instructions for proper screening of sales and instructions on the methods for use of sales in ratio studies enhance the CAD's ability to consistently apply sales. Lack of written validation procedures contributes to Starr CAD's levels of market value that do not meet Texas requirements, as reflected in the PVS.

Some CADs send out sales surveys to both buyers and sellers within 30 days of the sale and have indicated an increase in responses due to the timeliness of the request and the fact that it contacts both buyers and sellers. The Comptroller's initial review also gave Starr CAD the option of providing the state with deed information, which the state could then use to give the CAD confirmed sales data.

RECOMMENDATION 4
Develop written procedures for gathering and verifying sales data.

The CAD should consider processes other CADs use to increase sales reporting.

FINDING
Starr CAD does not generate ratio study reports, despite having a new software system that could generate these reports.

Starr CAD's appraisal staff does not use locally generated ratio studies to adjust unit value schedules for its cost approach; instead, the CAD updates its cost schedules from the previous year's PVS.

The CAMA system provides limited stratification options within the ratio study. Stratification provides the flexibility to determine ratios in various subsets of sales such as neighborhoods, building structural classifications, etc. A lack of locally performed ratio studies contributes to land and building cost schedules that are not properly oriented toward variations within the county's real estate market. Running ratio studies using current CAMA software can help ensure property values that are consistent with current market trends and meet Texas' required market value level within the CAD. Current, valid ratio studies are necessary to keep real property values current.

Starr CAD indicated it plans to upgrade the CAMA system for its 2009 appraisal cycle.

Ratio studies perform the following:

• identify neighborhoods that need appraisal maintenance;
• identify outliers where price and CAD property records are not compatible;
• calibrate the contribution of land and building characteristics to market value;
• consider updates to existing appraisal methods; and
• indicate when use of alternative appraisal approaches is appropriate.

RECOMMENDATION 5
Upgrade the CAMA system with an adequate ratio studies module and train appraisers on development, operation and use of internal ratio studies.

This training should include written, detailed parameters for various sub-markets; how to correctly apply results to appraisal valuation approaches; and how to use ratio studies for quality control of values.

FINDING
Starr CAD's appraisal operations do not follow its reappraisal plan.

Property Tax Code Section 25.18(b) defines what should be contained in a CAD's reappraisal plans including the following:

Starr CAD's reappraisal plan describes an ideal process used to value property in its reappraisal cycle. The CAD's reappraisal plan describes independent performance testing in its introduction; performance testing in the individual value review procedures; performance tests in the residential valuation process section; performance tests and sales ratio studies in the commercial and industrial valuation process section; and statistical analysis and performance tests/ratio studies in its business personal property valuation process section.

Under appraisal frequency and method summary, the plan indicates that:

Exterior pictures are taken of homes every other year. Every subdivision is statistically analyzed annually to ensure that sales that have occurred in the subdivision during the past 12 months are within a +-3% range of appraised value.

During the field inspection for the ASR sample properties, the CAD provided property record cards but no pictures of residential property.

The reappraisal plan's data collection procedures subsection, states:

Appraisers of real estate and business personal property conduct field inspections and record information using a pen pad device that holds all data dealing with the property and allows for the entry of corrections and additions that the appraiser may find in his or her field inspection.

During the field inspection for the ASR audit properties, the CAD did not use pen pad devices. All records were printed or copied in the office for use in the field. In the self-evaluation questionnaire, Starr CAD indicates that is does not have handheld computers for data collection.

The reappraisal plan's data collection section also states, "A quality assurance process exists through supervisory review of the work being performed by the field appraisers." In the data maintenance section, the reappraisal plan states, "Data updates and file modification for property descriptions and input accuracy is conducted as the responsibility of the field appraiser and appraisal supervisor."

Starr CAD's chief appraiser and deputy chief appraiser did not know that situs (property street address), building condition and year built were missing from most records in the ASR sample. There are accounts in the sample containing only a site value without land characteristics or value calculation lines. There is no quality control documentation to indicate Starr CAD systematically applies the appraisal review process. The CAD indicated this information is contained in the old, permanent cards and fieldwork, but that it needs to enter it into the CAMA system as well.

Starr CAD's reappraisal plan discusses area analysis and neighborhood market analysis, but the audit sample accounts do not have designated neighborhoods or neighborhood percentage adjustments.

The CAD's reappraisal plan describes the commercial and industrial property appraisal process and lists the income and sales comparison approaches as part of the CAD's primary appraisal approach. The residential appraisal section includes market and cost reconciliation and valuation. Starr CAD, however, only uses the cost approach, and its CAMA system only has a cost approach valuation module.

Starr CAD's reappraisal plan provides a set of goals for future reappraisals, but does not relate to the CAD's current operational circumstances for the 2007 assessment roll.

Lack of execution of reappraisal planning by Starr CAD has:

• resulted in valuation inconsistencies;
• impeded planned activities within the annual reappraisal cycle; and
• compromised equal and uniform appraisals.

By revising its planning process to develop a reappraisal plan that overcomes current operational shortcomings, Starr CAD can appraise all property equitably and uniformly.

IAAO's text, Property Appraisal and Assessment Administration, points out that every CAD "must prepare for periodic reappraisals and the upgrading of its mass appraisal system." The text adds that:

...a reappraisal requires careful planning and a major commitment of resources. Nevertheless, the resulting improvements in valuation uniformity and related benefits should justify the time and expense.

RECOMMENDATION 6
Revise operating procedures to reflect the elements of the reappraisal plan and execute the reappraisal plan as intended during the upcoming reappraisal year.

2.3
Other Recommendation

During the review process, PTAD identified a certain management and operational issue not directly related to the appraisal process, but that could indirectly affect the CAD's ability to conduct appraisals accurately and consistently. Starr CAD is not obligated to implement this recommendation, but the Comptroller provides it here for consideration as an additional way to enhance operational effectiveness and efficiency. This recommendation, however, may advise compliance with existing laws. Appraisal districts, as Texas governmental entities, are required to comply with all applicable laws.

FINDING
Starr CAD does not comply with the Comptroller's Property Tax Rule 9.3002, concerning maps.

Rule 9.3002 addresses mapping as follows:

Starr CAD has not added land identification and boundary information to its geographic information system (GIS). The previous ASR recommended the CAD implement a complete automated mapping system, integrate the mapping and appraisal systems and acquire the proper hardware for all staff. In June 2006, the chief appraiser informally solicited proposals for a mapping system. He considered proposals from firms with experience in the field. The CAD received three bids and selected a firm with the second-lowest price but that had an office in nearby McAllen. The branch office in McAllen was the key factor in selecting the firm. The board approved hiring the firm on Nov. 2, 2006. The chief appraiser signed the contract on Nov. 30, 2006. Implementation began in December 2006 with an expected completion date in 2008.

Pursuant to the follow-up visit, PTAD encouraged the chief appraiser to develop quarterly status reports on the progress of the mapping system and to send quarterly status reports to the PTAD until the CAD completes implementation.

The contract's letter of transmittal spreads payments over a two-year period, but does not tie payments to deliverables and does not include provisions to monitor the contract. Under the contract, the engineering firm will digitize property parcels from legal descriptions, update base maps with parcels derived from National Agriculture Imagery Program 2004 Aerial Photography and provide the CAD with non-referenced properties for further research. When completed, this will provide Starr CAD with a comprehensive mapping system and it will improve property discovery.

Since the GIS is not complete, field appraisers must use the subdivision plats to identify properties for assessment. Most improved properties reviewed during the field audit did not have house numbers on the buildings or property to assist with identification. Using various subdivision plats makes it difficult for field appraisers to properly identify property within the CAD. During the ASR team's inspection of sample property, the field appraisers were unable to identify and locate a few properties. This resulted in appraisers substituting properties from the PVS that appraisers were able to locate in place of properties they could not locate.

Some improvements are located on property without a clear, legal chain of titles, which hampers the CAD's ability to identify and appraise property. In the mid 1900s, land speculators sold properties without clear historical ownership. Buyers have developed some of this land with residential and commercial structures and have paid property taxes on these properties. The inability to provide a clear title affects these properties' current market values. These areas also have limited government services such as paved roads. The GIS contractor is loading deed information into the GIS system that can assist the CAD to identify these areas with ownership defects on its property records.

The south boundary of Starr County is the Rio Grande River. Although the county is generally arid land, the county has experienced flash flooding in several areas as water moves rapidly down toward the Rio Grande River. These flash flood prone areas, located in identified flood plains, affect property values. The GIS and CAMA system's property records should contain information about these areas. The CAD should be able to add Starr County's portion of electronic national flood plain maps to its GIS system so it can cross-reference, through a spatial matching process, the flood areas to Starr CAD's property boundary lines and account numbers in the CAMA system. Starr CAD uses aerial maps to locate lot boundaries for its GIS. The engineering firm will overlay these aerial maps on the county map and will become part of Starr CAD's publicly available GIS. These maps will be available in the CAD's mapping room.

RECOMMENDATION 7
Complete the development of the GIS.

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