I am writing as a concerned citizen with regard to HB2245. Given the need for affordable housing in Virginia as a whole, but especially in the Richmond Metro area, I feel that passage of this bill will not only disincentivize localities in this region from providing much needed housing but will incentivize affordable-housing owners to continually appeal their assessments yearly, burdening local taxpayers with the hefty bills invoiced by tax attorneys which are easily in the tens of thousands of dollars per case. By taking the financial burden off of landlords in this manner, you are allowing the bill to be passed on to taxpayers, thus taking money that could be earmarked for affordable housing and essentially placing it in the hands of those that do not need it, namely owners of affordable housing. Can you not see how this would negatively affect those that are already in need of affordable housing? If you can't build more housing because a locality is mired in debt by attorney fees, or fearful of such a prospect, then how will you provide the housing that's so desperately needed? As the bill is currently written, ANY change in the assessment is taken as evidence of a "win" by the landlords/owners. This means a factual error that results in the amendment of the assessment counts as a win and thus the locality pays the "reasonable" attorney fees. Does that seem fair to your constituents? I certainly don't think so. Also, as it stands assessors are hamstrung by being required to utilize only the income approach to value, which is one of three approaches to value recognized and utilized by USPAP (Uniform Standards for Professional Appraisal Practice). USPAP, in case you weren’t aware, was adopted in 1989 by Congress as the standard for all manner of appraisal services, and the standard to which all licensed and certified appraisers must comply in order to maintain professional licensure. Per USPAP, the APPROPRIATE approach to value is to be utilized when assessing the value of ANY property. This brings me to my final points: 1) Simply put, the income approach is not always the appropriate approach to value for affordable housing properties. By forcing appraisers to comply with a misunderstanding of appraisal theory and practice, you risk running afoul of USPAP mandates. 2) Given the amount of appraisers in the state that are licensed by the DPOR under USPAP guidelines, are you asking appraisers to risk their licenses and thus their careers in order to comply to a poorly thought out piece of legislation? In conclusion, it is my opinion that you are punishing your constituents in a multi-fold manner. You are punishing localities by disincentivizing the ability of localities to afford and/or want more affordable housing, thus punishing those who need it. You are punishing professional appraisers by mandating that they run afoul of USPAP mandates and risk their careers. Finally, you are incentivizing individuals who own affordable housing, a group notoriously known to never take advantage of their tenants through fees over and above the controlled rents those tenants pay, and who always keep their properties in livable condition, never charging for services that are never done, and never reaping the benefits of a broken system. By passing this bill you will only be enriching the already rich and further fracturing a broken system, which I would hope is contrary to your cause.

Comments Document

The attachment provided is a dissenting opinion of the adoption of HB2245-Callsen.

Section F Should be removed from this legislation. No Virginia citizen should be responsible for paying the attorney fees for an appeal. Furthermore, by allowing this for affordable housing will only open up this option to other owners when seeking relief via the appeal process. This is taking the tax burden of a single owner and shifting it to all owners including those needing affordable housing.

HB 424 - Exempt Disabled Veterans From Tolls Can we hurry up an pass this. The VA is in DC. Traffic is a nightmare. Tolls insanely expensive, for veterans on a fixed income. Other states have this, why is rich Virginia so slow to implement this.

Virginia First Cities is acutely aware of the need to solve the assessment of affordable housing in our 18 member cities and we are committed to finding a solution that both works for our assessors and for our housing goals. We thank the patron and housing advocates for this bill, but barring amendments, we must oppose HB 2245. We are committed to finding solutions that work for our assessors and for our affordable housing goals. For example, the Short Form that is contemplated in the HB 2245 would omit and/or compromise the integrity of the income/expense data being submitted. Its beneficial to get the official certified income and expense data as kept by accounting methods and not transposed onto a Short Form. It would eliminate important data used in the Income Approach. There’s quite a bit to be worked through here but it’s not currently in the HB 2245 bill. Likewise, we find it not in the interest of anyone to have the language regarding liability for attorney/legal fees. We hear from several of our member-city assessors that they cannot assess when they are not provided the requisite information with which to make the assessment. Again, there are issues to be worked out with this bill, but until they are, sadly, we must oppose the bill.

The city of Newport News is opposed to this bill in its current form. The short form that it suggests would omit and or compromise the integrity of the data being submitted. It is beneficial to get official certified income and expense data as kept by accounting methods and not transposed onto a short form; it would eliminate important data used in the income approach.

Per our City Assessor: "This part of the bill should be stricken. The bill also provides that the locality for which an assessment was performed by an assessor that failed to comply with the provisions of the bill shall reimburse an owner of property for reasonable attorney fees and costs incurred in bringing and prosecuting an appeal of such assessment if the owner wins the appeal. There is no incentive to provide the information, we send request every year and most "affordable housing" outside of PRHA do not respond, if they wish to leave this verbiage in the bill then they need to add something stating that if the information is not sent to the assessor in a timely manner, this provision does not apply. We shouldn't have to pay for their legal counsel when they don't provide the information. I have one right now that I don't get the information until after they get the notice when they have their attorney reach out about an appeal, then I finally get the needed information." Please Oppose this bill. Thank you

Comments Document

Please find the attached letter from Enterprise Community Partners in favor of HB 2245 - Affordable housing property tax assessment. Thank you for consideration.