HomeMy WebLinkAboutItem C: Ordinance Concerning Real Property Value-Added Charge
ECC
UGENE ITY OUNCIL
AIS
GENDA TEM UMMARY
Work Session: An Ordinance Establishing a Real Property Value-Added Charge;
Adding Sections 2.100, 2.105, 2.110 and 2.115 to the Eugene Code, 1971;
Amending Section 8.005 of that Code; and Adopting a Severability Clause
Meeting Date: December 11, 2006 Agenda Item Number: C
Department: Planning and Development/City Attorney Staff Contact: Susan Muir/Glenn Klein
www.eugene-or.gov Contact Telephone Number: 682-6077/682-5080
ISSUE STATEMENT
Under Ballot Measure 37, governments must pay compensation or waive regulations when certain
regulations restrict the use of property and reduce its value. The measure did not provide any funding
with which to pay those Measure 37 claims. The proposed ordinance would establish a real property
value-added charge to be paid when certain regulations increase the value of the property. Such a
charge would allow the City to create a fund with which to pay valid Measure 37 compensation claims.
BACKGROUND
The council’s first work session was held on January 25, 2006, at which it reviewed and discussed four
separate options for a possible fee or tax to fund payment of Measure 37 claims. Following additional
work sessions, the council directed the City Manager to bring back to the council for public hearing an
ordinance that would impose a charge of 25% of the increase in value when the increase was the result
of citizen-initiated requests for zone changes, plan designation changes, or a change in the Urban
Growth Boundary (UGB). The charge also would be imposed for those actions when initiated by the
City or other governmental entity, but only if the property owner submitted some type of application (for
example, building permit application) that could not have been approved without the City’s action
making a change in the zoning, Metro Plan, Refinement Plan or UGB.
On October 16, 2006, the council held a public hearing on the proposed ordinance, which is attached as
Attachment A to this Agenda Item Summary (AIS). After discussion and consideration of the testimony
presented at the public hearing, the council unanimously approved a motion to leave the record open
until 5:30 p.m. on October 30, 2006. In addition, following the public hearing, the council asked a
number of questions and directed that a work session be scheduled where staff could return to council
with answers to those questions. The balance of this section provides answers to the questions and
identifies some of the policy questions raised by the testimony. Some of the questions and comments by
councilors also sought amendments to the ordinance. Attached as Attachment B are suggested motions
to amend the ordinance based on the requests following the public hearing.
Is the real property value-added charge a “land use regulation” that would create new Measure 37 claims?
No. “Land use regulation” – for purposes of measure 37 – is defined as a land division ordinance, a
zoning ordinance, a transportation ordinance or a comprehensive plan. (The definition also includes
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additional types of regulations, but those apply only to the state or the regional government in the
Portland metro area.) This ordinance is none of those. Moreover, this ordinance does not restrict the
use of property, which is another requirement under Measure 37.
Is the charge subject to the property tax limits of Measure 5 and Measure 50?
No. Measures 5 and 50 limit “taxes on property.” A “tax on property” is defined for those measures as
a charge that is imposed directly on the property itself (like the library local option levy), or a charge
that is imposed on the owner of property as a direct consequence of ownership. The real property value
added charge is not imposed on the property, and is not imposed on the owner of property as a direct
consequence of ownership. Instead, the charge is imposed as a consequence of an “upzoning” that
increases the fair market value of the property.
Will any of the tasks on the Planning Commission’s work plan potentially create Measure 37 claims?
potential
Yes. The following high priority work tasks have the – depending on the ultimate policy
choices – to include components that could create Measure 37 claims: opportunity siting/infill
compatibility standards; mixed use centers; minor code amendments; downtown and courthouse
associated projects; south ridgeline habitat study; and Jefferson-Westside Neighborhood Metro plan
amendments.
For non-requested changes, is the change in value measured at the time of the change, or at the time
that the property owner takes advantage of the change?
As currently drafted, the ordinance would measure the change in value at the time that the council
amends the zone, the UGB or the refinement or metro plan designation.
Would a property owner be required to pay too much when property zoned agriculture is rezoned to R-1
(at time of annexation or otherwise), since the Assessor’s Office data on the value of property zone AG
underestimates the fair market value of that land?
No. Although the ordinance provides a “default” determination on the value of property (which is based
on data from the Assessor’s Office), the property owner has the option of rejecting that default
determination and submitting an appraisal that provides a more accurate measurement of the property’s
fair market value before the zone change (e.g., agriculture) and after (e.g., R-1). The assumption in the
question is that property zoned agriculture (if inside the UGB) is already selling for R-1 zoned prices. If
that is the case, then the property owner can submit an appraisal demonstrating that fact, and unless the
City obtains its own appraisal containing a different value, the value-added charge will be based on the
property owner’s appraisal, rather than the default value. (If the City obtains its own appraisal, then the
property owner can accept the value in the City’s appraisal, or can request that an independent hearings
officer hold a hearing and determine the correct value.)
How does the Assessor obtain its data and how accurate is that data?
Attached as Attachment C is a memorandum from Larry Hill that answers the question. The Assessor’s
data is by no means 100% accurate for every property at every moment in time. From staff’s
perspective, the lack of 100% accuracy should not matter since the property owner has the choice of
accepting the Assessor’s data, or submitting his/her own appraisal that more accurately identifies the
real market values.
Does the ordinance limit the use of the funds to payment of Measure 37 claims?
The intention – as directed by thecouncil – is certainly to limit the use of the funds. The purpose section
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– Section 2.100(1) – states that the purpose is “to develop a fund that can be used to pay compensation
when a valid Measure 37 is filed.” The ordinance, however, does not contain an explicit limitation.
Amendment 1A on Attachment B would add such an explicit limitation.
Can the purpose of the fund be expanded to include use of the funds to purchase conservation easements
in order to avoid the filing of and having to pay Measure 37 claims?
Yes. The council has the power to impose the value added charge and to use the funds to purchase
conservation easements. Amendment 1B on Attachment B would accomplish that purpose, as well as
explicitly limit the use of the funds to payment of compensation for valid Measure 37 claims or to
purchase conservation easements to avoid Measure 37 claims.
Can a property owner pay the charge at the time of sale, rather than at the time of the change in zoning,
UGB status or plan designation?
As drafted, the ordinance requires payment at the time of the change (for a requested change) or at the
time that the owner takes advantage of a change (for a non-requested change). The council could choose
to allow a property owner to pay at the time of sale. In order to ensure that the City received payment,
staff would recommend that the mechanism for such a deferred payment be similar to deferral of a local
improvement district assessment: the property owner is given a choice to pay now, or to sign an
agreement that gets recorded on the property requiring payment of the charge (plus interest).
Amendment #2 on Attachment B would accomplish that purpose.
Does the ordinance exempt land held by public entities or land zoned PL from payment of the value
added charge?
No. As presently drafted, the ordinance applies to publicly owned, as well as privately owned, land.
The council could choose to exempt land held by public entities if it wanted to do so.
Should the ordinance exempt zone changes which will conform a property’s zone to the property’s
Metro Plan designation?
The ordinance does not contain such an exemption, but the council could choose to exempt such zone
changes.
Should the ordinance apply only to those applications for amendments (to a property’s zone, UGB
status, or designation in the Metro Plan or a refinement plan) that are submitted after the effective date
of the ordinance?
As presently drafted, the ordinance would apply to any application that is pending as of the effective
date of the ordinance. The council could choose to have the ordinance apply only prospectively: i.e.,
only to those applications that are submitted after the effective date of this ordinance.
Should the ordinance apply only to “requested” changes, and not to “non-requested” changes?
As presently drafted, the ordinance applies to both. The council could choose to delete the provisions
related to non-requested changes.
Should the council postpone action on the ordinance until after the 2007 legislative session and after a
work group of interested parties (including such parties as 1000 Friends of Oregon, appraisers and the
Home Builders Association) can work with staff to develop an improved-version of the ordinance?
In the weeks following the public hearing, Susan Muir was contacted by Rob Zako and Rick Duncan
requesting an opportunity to meet to discuss some possible deficiencies in the ordinance. During and
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after that meeting, there were suggestions that adoption of the ordinance be postponed so that further
agreement on portions of the ordinance could be achieved. With additional time, and an opportunity to
see what the 2007 Legislature does, an ordinance might be developed that can have more widespread
support.
RELATED CITY POLICIES
As previously indicated, creation of a fund to pay compensation for valid Measure 37 claims could help
the City preserve its regulatory authority under its Land Use Code (Chapter 9).
COUNCIL OPTIONS
The council may:
1. Adopt the ordinance as drafted;
2. Amend the ordinance and then adopt it;
3. Provide direction to schedule another work session on the proposed ordinance following the 2007
legislative session; or
4. Take no further action.
CITY MANAGER’S RECOMMENDATION
In light of the suggestion from a variety of interested parties for more time to improve the ordinance, the
City Manager recommends that the council defer action on this ordinance.
SUGGESTED MOTION
I move that this ordinance be scheduled for a work session following the 2007 legislative session.
ATTACHMENTS
A. Proposed Ordinance.
B. Requested amendments
C. Memo from Larry Hill regarding Assessor data.
FOR MORE INFORMATION
Staff Contact: Susan Muir, Executive Director
Telephone: 682-6077
Staff E-Mail: susan.l.muir@ci.eugene.or.us
City Attorney: Glenn Klein
Telephone: 682-5080
Staff E-Mail: glenn.klein@harrang.com
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ATTACHMENT A
ORDINANCE NO. __________
AN ORDINANCE ESTABLISHING A REAL PROPERTY VALUE-ADDED
CHARGE; ADDING SECTIONS 2.100, 2.105, 2.110 AND 2.115 TO THE
EUGENE CODE, 1971; AMENDING SECTION 8.005 OF THAT CODE;
AND ADOPTING A SEVERABILITY CLAUSE.
Section 1,
The following caption and Sections 2.100, 2.105, 2.110 and 2.115
are added to the Eugene Code, 1971, to provide:
REAL PROPERTY VALUE-ADDED CHARGE
2.100 Real Property Value-Added Charge – Establishment.
(1) Purpose. Measure 37 requires governments either to compensate
property owners when certain regulations reduce the real market
value of real property, or to waive those regulations. Sections 2.070
through 2.095 of this code establish a process for the city to follow in
processing those Measure 37 claims. Measure 37, however, does
not provide any funds to pay compensation. Under certain
circumstances, the city takes regulatory action that increases the
real market value of real property, including changes in the zoning of
real property and changes in a property’s designation in the
Metropolitan Area General Plan (“Metro Plan”) or a refinement plan.
When a property owner requests such a change, or takes advantage
of such a change initiated by the city, the city should receive a
portion of that increase in value in order to develop a fund that can
be used to pay compensation when a valid Measure 37 claim is filed.
(2) Charge Imposed. A real property value-added charge is imposed on
the increase in real market value, measured as set forth in
subsection (4), whenever the city approves one of the actions listed
in subsection (3) after [the date of adoption of this ordinance]. The
amount of the charge shall be equal to 25% of the increase in real
market value resulting from the action.
(3)Regulatory Actions Triggering Charge.
(a) The charge created by subsection (2) shall be imposed on the
following actions when requested by the property owner or by
someone on behalf of the property owner:
1. A zone change;
2. An amendment to the Metro Plan or refinement plan
designation for the property; or
3. An amendment to the Urban Growth Boundary (“UGB”).
(b) Where a zone change, amendment to the Metro Plan or
refinement plan designation, or amendment to the UGB was
Ordinance -
1
ATTACHMENT A
not requested by or on behalf of a property owner, and instead
was initiated by the city or another governmental entity, the
charge shall not be imposed at the time of that change or
amendment. Instead, the charge shall be imposed if, and at
the time that, the property owner submits an application to the
city for an approval – such as a development permit, as
defined in section 9.0500 of this code, or land use approval -
that could not be approved but for the zone change, Metro
Plan or refinement plan amendment or UGB amendment.
(4) Measure of Increase in Real Market Value, The increase, if any, in the
real market value of the property shall be measured by the change in
the real market value of the land under its new zone, designation or
UGB status, as compared to its real market value under its prior
zone, designation or UGB status. The change in real market value
shall be determined as provided in section 2.105 of this code.
2.105 Real Property Value-Added Charge – Determining Changes in Real Market
Value.
(1) The city manager shall adopt an administrative rule pursuant to
section 2.019 of this code that establishes a per acre real market
value for different zones and plan designations for property inside
the city. The values adopted by the manager shall be based on the
median real market value per acre for land in the city with that zone
or designation according to data maintained by Lane County
Assessment and Taxation. The city manager may update the values
contained in the administrative rule whenever the manager
determines that the most recent assessment and taxation data
justifies updating the administrative rule.
(2) Except as provided in subsections (4) through (7) of this section, the
per-acre values established by this administrative rule shall be used
to determine the value of the property following the change in
zoning, plan designation or UGB status, by multiplying the
applicable per-acre value times the acreage of the property subject
to the zone change, or amendment to the plan designation or UGB.
(3)Except as provided in subsections (4) through (7) of this section, the
pre-change value of the property shall be equal to the real market
value assigned to the land by Lane County Assessment and Taxation
immediately prior to its rezoning or redesignation.
(4) If a property owner disagrees with the real market values as
determined under subsections (1) through (3) of this section, the
property owner may obtain and submit to the city an appraisal for the
property from an appraiser certified by the State of Oregon as a
General Appraiser. The appraisal must comply to the maximum
extent possible with the Uniform Standards of Professional Appraisal
Practice, and shall include appraised amounts for the property both
Ordinance -
2
ATTACHMENT A
(a) prior to the change in zoning, plan designation or UGB status,
and (b) subsequent to the change.
(5) If a property owner obtains and submits an appraisal as provided in
subsection (4) of this section, then the city shall either accept the
values contained in the appraisal, or obtain its own appraisal. If the
city accepts the values, then the value-added charge shall be based
on the difference between the pre-change and post-change values
contained in that appraisal. If the city chooses to obtain its own
appraisal, the city’s appraisal shall meet the same standards as
required for the property owner’s appraisal.
(6)If the city chooses to obtain its own appraisal, the city shall provide
to the property owner a notice of determination as to the real market
values and a copy of the appraisal on which that determination is
based. Within 15 days following the property owner’s receipt of the
city’s determination and appraisal, the property owner shall decide
whether to (a) accept the real market values as determined by the
city, or (b) appeal the issue in accordance with section 2.021 of this
code. Unless the owner submits the appeal under section 2.021
within 15 days of the receipt of the city’s determination and
appraisal, the city’s determination shall be final and not subject to
further review.
(7)If the property owner submits a timely appeal request under section
2.021, a hearings officer shall hold a hearing and issue a decision on
the change in value. The hearings officer’s decision shall be the
city’s final decision on the matter.
2.110 Real Property Value-Added Charge – Requested Changes .
(1) At the time a property owner or someone on behalf of a property
owner submits an application for a zone change, plan amendment or
UGB amendment, the applicant shall deposit with the city:
(a) The amount of the charge as determined in accordance with
subsections (1) through (3) of section 2.105 of this code; or
(b) The amount of the charge based on an appraisal performed
under subsection (4) of section 2.105 of this code, together
with a copy of the appraisal required under that subsection.
If the application for a zone change, plan amendment or UGB
amendment is denied, the amount of the charge deposited shall be
returned to the applicant.
(2) If the applicant fails to deposit the charge as required by subsection
(1), the city manager shall determine the amount that is due based on
subsections (1) through (3) of section 2.105 of this code, and shall
send written notice of that determination to the property owner. The
amount due as determined by the city manager in accordance with
subsections (1) through (3) shall be final, unless the property owner
appeals that determination pursuant to section 2.021 of this code.
Ordinance -
3
ATTACHMENT A
The sole basis for an appeal shall be that the manager erred (a) in
applying the administrative rule adopted under subsection (1) of
section 2.105, or (b) in reviewing the information from Lane County
Assessment and Taxation related to the most recent determination
as to the real market value. For purposes of this appeal, the real
market values contained in the administrative order and in the
records of Lane County Assessment and Taxation shall be
conclusively presumed correct. No appraisal or other information
may be presented to or considered by the hearings officer. The city
manager shall forward the notice of determination of the amount of
the charge and requirement for its deposit to the applicant. The
notice shall contain a statement that failure to submit the deposit by
the date set forth in the notice will result in the imposition of a lien
against the applicant’s property, which shall be recorded in the city’s
lien docket.
(3) If the applicant submits a deposit under subsection (1) of this
section based on an appraisal, the city manager shall inform the
applicant, as provided for in subsection (5) of section 2.105, whether
the city accepts the real market values contained in the applicant’s
appraisal. If the city does not accept those values, and if the final
determination of real market values (after the city obtains an
appraisal and possibly after a hearing) establishes values that result
in a greater change in value than calculated by the applicant, the
applicant shall submit the additional value-added charge that is due.
Failure to do so shall result in the imposition of a lien for the
additional amount due, which shall be recorded in the city’s lien
docket.
2.115 Real Property Value-Added Charge – Non-Requested Changes.
(1) Purpose. This section governs the imposition of the real property
value-added charge when the change in zoning, plan designation or
UGB status is not one that had been requested by or on behalf of the
property owner. In this situation, the charge shall be imposed only if
a property owner decides to seek a regulatory approval – such as
approval of a development permit, land division, or other land use
permit – that could not be approved if the change in zoning, plan
designation or UGB status had not been approved.
(2) The city shall forward to a property owner who becomes subject to a
real property value-added charge as a result of an action initiated by
the city under section 2.100(3)(b) a notice identifying a potential real
property value-added charge. The charge will not become due and
payable until such time as the property owner takes some action
such as the submission of an application for a development or land
use permit that relies upon and takes advantage of the city-initiated
action. If there are multiple city-initiated actions involving the same
Ordinance -
4
ATTACHMENT A
property occurring at different times, the charge shall be computed
for each individual action as though it were being imposed at that
time. The notice shall be recorded in the city’s lien docket as a
potential future charge upon the property.
(3) Upon receipt of a notice under subsection (2), a property owner who
disagrees with the city’s valuations may appeal the city’s
determination to a hearings officer in accordance with the provisions
of section 2.021 of this code. The decision of the hearings officer is
final. If the hearings officer’s decision establishes a different amount
of value-added charge than initially established by the city manager,
the lien recorded in the city’s lien docket shall be corrected to reflect
the amount established by the hearings officer.
Section 2.
Subsection (11) of Section 8.005 of the Eugene Code, 1971, is
amended to provide:
8.005 Administrative Code
.
(11)
Applications for permit. To obtain a permit, the applicant shall complete
and file an application and related materials as required by the city
manager in regulations developed pursuant to this code. If the property
is subject to a real property value-added charge under sections 2.100
through 2.115 of this code, no application may be submitted, or
accepted by the city, unless the applicant has paid to the city the
amount of the value-added charge.
Section 3.
If any section, subsection, sentence, clause, phrase, or portion of this
ordinance is for any reason held invalid or unconstitutional by any court of competent
jurisdiction, that portion shall be deemed a separate, distinct, and independent provision
and that holding shall not affect the validity of the remaining portions of this Ordinance.
Section 4.
Notwithstanding the effective date for imposing the real property
value-added charge as set forth in the proposed section 2.100(2), the charge shall be
imposed with respect to any application for a zone change or change in plan
designation pending upon the effective date of this ordinance. The City Manager shall
forward to any such applicant a notice setting forth the amount of the real property
value-added charge based on subsections (1) through (3) of section 2.105 of the
Ordinance -
5
ATTACHMENT A
Eugene Code, 1971. Any such applicant may choose to accept that amount, or
alternatively, obtain and submit to the city an appraisal pursuant to section 2.105(4). In
the event that the applicant submits such an appraisal, then subsections (5) through (7)
of section 2.105 also shall apply. No development permit, as defined by section 9.0500,
shall be issued until the charge has been deposited with the city.
Section 5.
The City Recorder, at the request of, or with the concurrence of the
City Attorney is authorized to administratively correct any reference errors contained
herein or in other provisions of the Eugene Code, 1971 to the provisions added,
amended or repealed herein.
Passed by the City Council this Approved by the Mayor this
____ day of ____________, 2006 ____ day of ______________, 2006
___________________________ _____________________________
City Recorder Mayor
Ordinance -
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ATTACHMENT B
Motion 1A – (Explicitly limits use of funds):
Move to amend the last sentence of Subsection (1) of Section 2.100 to provide:
“When a property owner requests such a change, or takes advantage of such a change
initiated by the city, the city should receive a portion of that increase in value in order to
develop a fund for payment of valid Measure 37 claims. The use of the funds received
shall be limited to the payment of compensation for a valid Measure 37 claim.”
[NOTE: ONLY Motion 1A or 1B should be made, but not both.]
Motion 1B – (Expands purpose for use of funds to include purchase of conservation easement,
and specifically limits use of funds to payment of claims and purchase of conservation
easements):
Move to amend the last sentence of Subsection (1) of Section 2.100 to provide:
“When a property owner requests such a change, or takes advantage of such a change
initiated by the city, the city should receive a portion of that increase in value in order to
develop a fund for payment of valid Measure 37 claims and purchase of conservation
easements in order to avoid Measure 37 claims. The use of the funds received shall be
limited to the purchase of such conservation easements or payment of compensation for
valid Measure 37 claims.”
Motion 2 – (Allow payment at time of sale):
Move to amend Section 2.110 by adding a new Subsection (4) and amending the lead
sentence of Subsection (1) to provide:
“(1) Except as provided in subsection (4) of this section, at the time a property owner
or someone on behalf of the property owner submits an application for a zone change,
plan amendment or UGB amendment, the applicant shall deposit with the city:”
“(4) In lieu of the deposit and payment required by subsection (1) of this section, an
applicant may elect to enter into a deferral agreement provided by the city that requires
payment of the charge, plus interest, upon the sale of the property. The agreement shall
be recorded in the Lane County Records.”
Move to amend Section 2.115 by adding a new Subsection (4) to provide:
“(4) A property owner who becomes subject to the real property value-added charge
under this section may elect to enter into a deferral agreement provided by the city that
ATTACHMENT B
requires payment of the charge, plus interest, upon the sale of the property. The
agreement shall be recorded in the Lane County Records.”
Move to amend Subsection (11) of Section 8.005 to provide:
(11)
Applications for permit. To obtain a permit, the applicant shall complete and file
an application and related materials as required by the city manager in regulations
If the property is subject to a real property
developed pursuant to this code.
value-added charge under sections 2.100 through 2.115 of this code, no
application may be submitted, or accepted by the city, unless the applicant has
paid to the city the amount of the value-added charge or has entered into an
agreement provided by the city that defers payment of the charge.
ATTACHMENT C
Central Services
Finance Division
Financial Analysis
City of Eugene
th
100 West 10 Ave, Suite 400
M
Eugene, Oregon 97401
EMORANDUM
(541) 682-8417
(541) 682-5802 FAX
www.ci.eugene.or.us
Date:
December 11, 2007
To: Mayor Piercy and City Councilors
From:
Larry Hill, Senior Financial Analyst, 682-5722
Subject:
Accuracy of the Real Market Values Assigned to Property, with Regard to a Proposed
Ordinance Establishing a Real Property Value-Added Charge.
This memo follows up on a question raised at the October 16, 2006 public hearing concerning the
accuracy of the Real Market Values. The proposed ordinance directs City staff to identify the Real Market
Value of subject property under the property’s current zone/plan designation, and estimate the average
A&T Real Market Value for the property under the proposed new zone/plan designation. The Charge
would be based on the difference between the two values.
Lane County Assessment & Taxation property value data would be used, together with data available
through LCOG on property zoning and plan designation. I have asked Lane County Assessment &
Taxation (A&T) to describe the accuracy of the Real Market Value (RMV) assigned to property. Deputy
Assessor Anette Spickard replied as follows:
"We are required by law to set the values of all property in the county to 100% of real market value as
of January 1 each year. We conduct mass appraisal and value large groups of similar properties
together. We use all three approaches to valuation; income, cost, and market, depending on the type of
property. Our data is accurate as of January 1 each year within + or - 10% on an individual property
which is the expected standard within the appraisal industry. If an owner disputes our accuracy, they
appeal to the Board of Property Tax Appeals and present evidence to show how our value is incorrect.
The Department of Revenue validates and confirms the [statistical] accuracy of our real market values
each year through the Assessor's Ratio Study.... So, in response to your question "how accurate is our
RMV?" my answer is very accurate to the extent that you remember our values are intended to reflect a
single point in time, January 1, for property taxation purposes only. Our values are not to be used in
lieu of a private fee appraisal for real estate financing, lending, banking or other transaction purposes.
Our values are not intended to reflect "real-time" market values of a property. For example when
taxpayers receive their tax statements at the end of this month, the RMV listed is as of 1/1/2006, which
is already 10 months out of date and was based on market activity from 2005 which was different than
the market that is occurring today."
In summary, A&T’s RMV for a property will generally lag current RMV by a year or more, and with
continuing increases in property values we can generally expect that current RMV will be higher on
average than will be reflected in A&T data. Note also that at the time each year’s values are established it
is possible that an individual property’s actual RMV may vary by as much as 10% from the RMV
assigned by A&T.