May 5, 2020

Honorable Jeff McClain

Ohio Tax Commissioner
30 East Broad Street, 22nd Floor
Columbus, Ohio 43215

Dear Commissioner McClain:

Pursuant to Ohio Revised Code 5713.01(B), I respectfully request a one-year extension for the
reappraisal of all property in Montgomery County. Good cause exists for this extraordinary request as it
is in the best interests of the residential and commercial property owners of Montgomery County as
well as the administration of the local property tax in Ohio.

The Tax Commissioner has ordered the Montgomery County Auditor to commence a reappraisal for Tax
Year 2020. I contracted with Lexur Appraisal Services with the approval of your office to conduct
reappraisal services related to this order. Ohio law requires every reappraisal to be based on evidence of
the fair market value of all properties, and it limits a County Auditor to consider only sales in the three
years prior to the tax lien date in the process of appraising properties.

In our case for 2020, to establish a taxable value for all properties in Montgomery County as of January
1, 2020, I must rely on sales in 2017, 2018, and 2019 only. Based upon that review, Montgomery County
has experienced a record number of sales and near-record sales prices, which will result in double-digit
percentage gains for property values in the vast majority of communities and double-digit increases for
thousands of individual property owners.

As we have done our work for the reappraisal, we have been preparing for how we will communicate
with our property owners about these huge increases. Typically, we would spend the spring and
summer months holding informal hearings and speaking to local governments, school boards, and
community groups of all types so that they can better understand the reappraisal process and how it
affects them.

We were in the planning stages of all of this while finalizing 2020 values, and then the COVID-19
pandemic arrived on our doorstep. Given social distancing protocols, our steps to communicate, engage,
and encourage public participation in the reappraisal process as we typically have done in the past will
be severely limited. I consider this to be a serious setback and will negatively impact overall results and
public perception. Considering the potential impact of the COVID-19 pandemic, it is my firm belief that
there is good cause to extend the reappraisal as it could have an adverse impact on citizens and
businesses who have been affected by this unprecedented economic shutdown.
I base all my valuation decisions on evidence as dictated by well-settled Ohio law and procedures set
forth by your office. But doing so in this case would be harmful to the local community that I serve. A
one-year extension would enable me to assess the impact of the economic shutdown on the commercial
and residential values in Montgomery County. This would provide those property owners and
businesses temporary relief from any increase in taxes at a time when our community’s economic health
hangs in the balance.

This extension will have the added benefit of contributing to the orderly review and administration of
revaluations by the Tax Commissioner. There are currently 13 counties who are required to conduct a
revaluation in 2020. An additional 28 must conduct a triennial update that must be approved by your
office.

In 2021 there are only 25 counties with either a reappraisal or a triennial update compared to 41 in
2020. Only five counties are conducting a revaluation in 2021, and 20 others will conduct a triennial
update.

By moving Montgomery County into the 2021 revaluation cycle, that would help balance the
administrative oversight duties of the Tax Commissioner. There have been attempts in the past to better
realign the counties with the intention of spreading the workload more evenly. With the challenges we
now face, this is the perfect time to move a large county into a year with fewer revaluations and
updates.

In conclusion, good cause does exist for this extension. This extra time will allow me to gather more
evidence about the impact of the COVID-19 pandemic on the local market, and it serves as a first step
toward realigning the number of counties in each reappraisal cycle. Most importantly, an extension will
provide the possibility of more public participation in the process next year, and it will better allow us to
determine property values that are fair and equitable.

Respectfully Submitted,

Karl Keith
Montgomery County Auditor