March 18th, 2020

Office of the Governor

Attn: Governor Greg Abbott
P.O. Box 12428
Austin, TX 78711-2428

Re: Comments on suspending certain requirements for county appraisal district's (CAD's) amid the
outbreak of COVID-19 (coronavirus).

Dear Governor Abbott,

I wanted to express my concerns regarding the suspension or modification of Tax Code Section 5.102,
25.18, 25.19, 26.01, 41.12, 41.44 for 2020 and its applicability to the COVID-19 (coronavirus) crisis.
CAD's across the state will inevitably see the effects of the current crisis and will be subjected to the
repercussions.

Reappraisal Activities: Texas Property Tax Code Section 25.18 requires appraisal districts to
implement a plan for reappraisal activities for all real and personal property in the district at least once
every three years. It is requested that the Governor declare that reappraisal activities statewide be
suspended for 2020 (including market value and appraised value) with exception of applicable ownership
updates, value added to the appraisal records due to new construction, and exemptions being modified,
added, or cancelled or in the case of reductions in value.

Suspension of the Property Value Study for 2020: Texas Government Code Section 403.302
requires the Comptroller to conduct a study to determine the total taxable value of all property in each
school district at least once every two years. The study is utilized to determine the taxable wealth of each
school district in the state and appraisal district appraisal performance. It is requested that the Governor
suspend the Property Value Study for 2020 and that it be resumed in 2021. The taxable value for each
school district for 2020 should be calculated based upon the most recent PVS conducted by the Comptroller.

Suspension of the MAP Review for 2020: Texas Property Tax Code Section 5.102 requires the
Comptroller of Public Accounts to review the governance of each appraisal district to determine compliance
with applicable standards, procedures, and methodology. The impact of the COVID- 19 outbreak and
health recommendations and declarations significantly affect the normal operations of appraisal districts as
they seek to limit public contact. It is requested that the Governor suspend section 5.102 of the tax code
for 2020.
 Delay of Notices: Tax code section 25.19 requires that by April 1 or as soon thereafter as
practicable of every year, appraisal districts are required to send notices of appraised value to property
owners if the value of their property increased, if the appraised value is greater than the rendered value,
the property was newly added to the roll, or an exemptions was cancelled or reduced. The sending of
appraisal notices to owners triggers significant activity and public traffic into appraisal district
offices. The demands of public contact increase significantly the potential for disease transmission. It is
requested that the Governor delay the date required that notices be sent until June 1, 2020 or after.

Delay Approval of the Appraisal Records and Certification of the Appraisal Roll: Section 41.12
requires the Appraisal Review Board in each county to hear and determine all timely filed protests and
approve the appraisal records. For most counties in the state, this requires substantial contact with the
public in person in large numbers in order to complete the protest cycle. Section 26.01 of the Tax Code
requires the Chief Appraiser to certify the appraisal roll to the taxing units by July 25 and it is assumed
that the protests are substantially complete, and the ARB has approved the appraisal records. In order to
limit public contact, it is requested that the Governor declare that the date by which ARBs are required to
hear and determine protests be moved from July 20, 2020 to August 15, 2020 or after. It is requested that
the Governor declare the date by which the chief appraiser is required to certify the roll in Section 26.01
be changed from July 25, 2020 to August 30, 2020.

Delay of Protest Deadline: Section 41.44 sets the protest deadline for owners entitled to a hearing
to determine a matter protested as May 15 or 30 days after a notice is mailed. The protest deadline
triggers significant contact with the public in the district offices and this significantly impacts the
potential for the spread of disease. It is requested that the Governor delay the protest deadline to June 1,
2020 or later.

I respectfully ask you to carefully consider the public policy issues presented in this case as well as the
precedent that would be set in the future.

Respectfully,

Keith Bell
State Representative