ASSESSMENT EQUITY IN NEW YORK:
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Distributional equity in real property taxation requires that properties of the same value be treated alike in terms of their assessments. New York State law (Section 305 of the Real Property Tax Law) stipulates that assessing jurisdictions must assess properties at a uniform percentage of value, and State courts have held that "value" means "market value." New York's two "special assessing units," New York City and Nassau County, must assess at a uniform percentage of market value within each of four specified property classes. This means that all parcels on the assessment roll (or, for special assessing units, within each class) should have the same, or at least very similar, assessment ratios (assessed value divided by market value). Each assessing unit has the right to choose the percentage of value to be used as an assessment standard. The New York State Board of Real Property Services regularly monitors the quality of assessments. An analysis of assessment uniformity is carried out each time the Board's staff completes a market value survey.1 The present report documents findings from the 2006 market value survey. Included are data for 983 non-village assessing units, which consist of 2 counties, 61 cities and 918 towns. 2006 Market Value Survey Data and Estimation Methodology For the 2006 market value survey, the level of assessment uniformity for each assessing unit was estimated using one of four possible approaches, as outlined below:
Measuring Assessment Uniformity The primary means of measuring assessment uniformity is a statistic known as the coefficient of dispersion (COD). The COD measures the extent to which the assessment ratios from a given roll exhibit dispersion around a midpoint. It is generally accepted that the median assessment ratio best serves as the midpoint or central tendency measure from which the average level of dispersion should be calculated. Assessing units with good assessing practices have low CODs, showing little deviation of individual assessment ratios from the median ratio. For example, if the median ratio for the parcels sampled in a given assessing unit is 50 percent, a house with a market value of $100,000 should be assessed at $50,000, a commercial property valued at $400,000 should be assessed at $200,000, and a $2,000,000 industrial parcel should be assessed at $1,000,000. If all other sampled parcels were similarly assessed at 50 percent of market value, the median ratio would also be 50 percent and the average deviation, as measured by the COD, would be zero. Conversely, an assessing unit with little assessment uniformity would have widely varying assessment ratios among the sampled parcels, resulting in high dispersion around the median ratio and, therefore, a high COD. Widely varying ratios result in unequal tax bills for properties of equal value. Examples 1 and 2 show two hypothetical assessing units, each attempting to assess properties at 80 percent of their market values. In Example 1, the assessed values range from 52 percent to 120 percent of market value, indicating a relatively high level of dispersion and poor assessment practices. Assessments such as these would result in an inequitable distribution of local taxes between property owners.
Example 2 shows a hypothetical case where assessments are more uniform. The assessment ratios range from 64 percent to 92 percent, and are closer to the target ratio of 80 percent, showing substantially less dispersion than occurred in Example 1. While some dispersion is evident, it is significantly lower than in the previous example and within an acceptable range when factors such as measurement error and valuation uncertainty are taken into account.
A second statistical measure of assessment uniformity, called the price-related differential (PRD)2 is also used in the current report for assessing units with no recent reassessment equity. The PRD is used to determine if there is a bias on an assessment roll toward systematic over-assessment of either high- or low-value properties in comparison to the average property. In computing the PRD, the simple mean of the assessment ratios is divided by the value-weighted mean ratio. If no bias exists, the two ratios should be close to each other, and the PRD should be near 1.00. This is referred to as "neutral" assessment practice, i.e., no price-related bias. However, if the simple mean ratio is considerably lower than the value-weighted mean, a low PRD results (less than 1.00). In this case, there is said to be a bias toward "progressivity," that is, higher-value properties are being over-assessed and lower-value properties are being under-assessed. In the opposite situation, where the PRD is high (greater than 1.00), "regressive" assessing is evident. In other words, lower-value properties are being relatively over-assessed and higher-value properties are being relatively under-assessed. The International Association of Assessing Officers (IAAO) has established a range for the PRD which denotes quality practices, i.e., neutral assessing: the PRD must fall in the range 0.98 to 1.03 to be considered acceptable. Assessment Uniformity Criteria Upon the completion of a market value survey, two coefficients of dispersion are calculated for the assessing units with no recent reassessment activity, one for residential property alone and one for all property classes combined. To evaluate the CODs calculated in this process, they must be compared to accepted standards of assessment uniformity. The International Association of Assessing Officers, in its book entitled Property Appraisal and Assessment Administration (1990) and its Standard on Ratio Studies (1999), has recognized that the ability of an assessing unit to attain uniformity is affected by several factors, such as the type of property, the degree of diversity of properties, and the relative ages of structures. The IAAO recommends a range of acceptable COD values, based upon an assessing unit's property composition and characteristics, as well as the increased difficulty experienced in assessing classes of property other than residential. IAAO standards are summarized in Table 1a. In its work with various types of assessing units, the State Board has found that the more rural areas, where there are relatively few sales and properties are more heterogeneous; pose greater difficulty in establishing accurate assessments and market values. Thus, in measuring assessment uniformity, the Board has taken the view that somewhat higher COD levels would be acceptable in areas with rural characteristics as contrasted with urban areas. These standards are summarized in Table 1b. In determining the number of assessing units achieving equity for purposes of this report, the standards in Table 1b were applied.
Coefficient of Dispersion Results For the 2006 market survey, the median residential COD among the sampled assessing units was 16.31, and the median for all property classes combined was 18.22.3 . In other words, half the sampled assessing units achieved greater uniformity than indicated by these median values, and half achieved less. The range in the all-property COD was 7.00 to 175.45. For the residential COD, the range among assessing units was 5.40 to 41.49. The COD results presented herein are point estimates. If the estimation were replicated using an alternative data set, it is likely that somewhat different figures would be obtained due to sampling error. Gloudemans, an expert in the field, has proposed a confidence interval approach to recognize the problem of sampling error. His approach results in a range within which the COD estimate will fall with a known probability. However, the approach does not obviate the need for making point estimates of the COD.4 Table 2 summarizes the 2006 COD information according to type of assessing unit, as measured by population density, and the State Board COD standards shown in Table 1b. Nearly 50 percent of the sampled assessing units had 2006 CODs that reflected uniform assessing practices for the entire roll.
Table 3 shows the combined results for sampled and non-sampled assessing units. When the non-sampled units -- those for which a recent reassessment program was reviewed and verified -- are combined with sampled units achieving satisfactory uniformity, a total of 759 (77.2%) of the state's assessing units had high quality assessment rolls. This is roughly comparable to the 80 percent found to be equitable in the 2005 survey analysis, and the slight decline from 2005 no doubt reflects the increased difficulty assessors are experiencing in their efforts to maintain equity during a time of rapidly rising residential property values in many areas of the state.
Another view of the quality of assessment rolls can be obtained from analysis of the level of assessment reflected on the roll, as contrasted with the degree of uniformity. Table 4 shows the distribution of 2006 equalization rates, which reflect the average percentage of market value used in assessing. The data indicate that about two-thirds of all assessing units now have assessments that are at least 75 percent of current market value. Although there are a few assessing units with assessments that are well below market value but which are still uniform and equitable, experience has demonstrated that current market assessments are strongly correlated with equity, and the level of assessment findings thus support the Table 3 data on assessment uniformity.
Figure 1 shows the trend in assessment uniformity among New York assessing units since 1980. In the 1980s, only about 10 percent of all assessing units had acceptable uniformity. Dramatic improvement occurred in the early 1990s, however, and this improving trend continues today with close to 80 percent of all assessing units now assessing uniformly.
Price-Related Differential Results As indicated earlier, another important summary statistic for assessment performance is the value-related index, called the price-related differential (PRD). The PRD is calculated by dividing the simple mean assessment ratio by the weighted mean ratio, where the weighted mean is the sum of assessed values divided by the sum of appraised values. The simple mean counts the ratio of each property equally regardless of the property's value, whereas the weighted mean counts each ratio differently, weighting ratios of higher-value properties more heavily, in proportion to their dollar value. If no assessment bias exists, the two values should be equal, producing an index of 1.00. Where there is evidence of a bias in favor of under-assessing the higher-value properties relative to the lower-value ones, the simple mean will be higher than the value-weighted mean, producing an index greater than 1.00 (regressivity). The reverse will be true in cases of over-assessment of high-value properties relative to those of low-value (progressivity). As shown in Table 1a, IAAO standards require that the PRD have a value between .98 and 1.03 for neutral assessing. Table 5 summarizes the extent of value-related equity as measured by the PRD for the sampled assessing units. Over 55 percent of them assessed residential property in a neutral manner: they generally did not tend to favor either high- or low-value properties. However, about 45 percent tended to over-assess low-value homes relative to high-value homes, while only three units tended to do the reverse. These results are about the same (as measured by the PRD) as found in the prior market value survey. This result is thought to reflect the strong residential real estate market conditions in many parts of the state, and the differential effects that such markets can have on parcels of different values. When all property classes are combined, the situation changes significantly. Table 5 shows that 21 percent of the assessing units in question use assessing practices that are biased toward over-assessment of higher-value properties, indicating over-assessment of the non-residential classes (generally industrial, commercial and utility property). About 34 percent demonstrate the opposite behavior, regressive assessing, meaning that they tend to overvalue the lower-priced properties (generally vacant land). The remaining 45 percent of the assessing units assess in a neutral manner with respect to value when all property classes are considered together.
Recent Reassessment Activity Subsequent to the 2006 Market Survey Approximately 16 percent (72) of the 443 assessing units for which CODs and PRDs were calculated have conducted or plan to conduct a reassessment on a roll subsequent to the one which was utilized in the 2006 survey, either in 2007 or 2008. For these assessing units, the COD and PRD estimates contained in this report are a measure of past assessment equity only; the level of uniformity on the newer roll may well be significantly improved from the level on the roll evaluated. Of the 540 assessing units for which recent reassessment projects were reviewed for the 2006 market survey, 339 have a subsequent reassessment project scheduled in 2007 or 2008. Thus, 63 percent of those that have already taken steps to maintain equitable assessing practices are projecting that they will reassess again in the next few years. The strong pace of reassessment activity in New York at the present time is also evident from the information shown in Figure 2 regarding localities that perform annual reassessment. As of January 2007, some 271 assessing units are committed to updating their assessment rolls on an annual basis, thus ensuring that equity will be maintained as market conditions change. Assessing Units Not Meeting Equity Standards Table 6 presents a listing of those assessing units not meeting the all-property COD standards outlined earlier in this report, or not having conducted a recent reassessment program.
1 This analysis is required by Section 1200 of the Real Property Tax Law.
2This statistic is sometimes referred to as the index of regressivity. 3The special assessing units of New York City and Nassau County are excluded in calculating the median COD because they use a classified assessing system.
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