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Report Number: CS 18-03
Date: March 21, 2003
CONFIDENTIAL REPORT TO FINANCE &
OPERATIONS COMMITTEE
From:
Gillis A. Paterson
Director, Corporate Services & Treasurer
Subject:
Filing of Assessment Appeals
Recommendation:
1. It is recommended that Report CS 18-03 of the Director, Corporate Services &
Treasurer be received and that;
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2. Council authorize the Director, Corporate Services & Treasurer to proceed to direct
the firm of Poole Milligan LLP to file Assessment Appeals for 2003 for Roll Number
1801 020 022 06800 0000 (OPG - Pickering Nuclear Facility) and for Roll Number
1801 020 022 09100 0000 (901 McKay Road) and any other assessment appeals
necessary to protect the financial interests (tax base) of the municipality;
3. Council confirm the actions of the Director of Corporate Services & Treasurer in the
filing of the Assessment Appeals for Roll Number 1801 020 022 06800 0000 for the
years 1999 to 2002 inclusive, and for Roll Number 1801 020 022 09100 0000 for
the year 2002 and all related litigation matters; and,
4. the appropriate officials of the City of Pickering be authorized to take the necessary
action to give effect hereto.
Executive Summary: Several property tax agents in various parts of Ontario have
recently brought Motions forward to the Assessment Review Board (ARB) asking the
ARB to dismiss assessment appeals filed by the Tax Collector or Treasurer of the
municipality. In their motion, the Agents state that in their opinion, staff did not have the
approval of Council to file the appeal. While these Motions have not received a ruling
as yet and while the by-law appointing the Treasurer should be sufficient it has been
recommended by our Legal Counsel that the above Recommendations should be
adopted by Council before March 31, 2003 in order to ensure the City's interests are
protected.
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Confidential Report to Finance &
Operations Committee CS 18-03
Date: March 21,2003
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Subject: Filing of Assessment Appeals
Page 2
Financial Implications: The filing of these appeals will protect the City's financial
plan for the current and future years. The 2003 Budget currently includes an estimated
$870,000 as additional revenue due to the OPG appeal. The cost of the appeals is
funded from the Assessment Appeal Reserve in the Corporate Services Department
and therefore, there is no direct impact on the 2003 tax levy.
Background: The City's primary financial resource is the property tax base which
funds approximately 62% of the City's 2003 current expenditures. In recent years in
municipalities across Ontario many commercial and industrial taxpayers have hired
consultants to appeal their assessment which in some situations has resulted in a
decrease in property tax revenue. For the 2002 taxation year, assessment reductions in
Pickering (due to Assessment Appeals and Minutes of Settlement) were approximately
$17.7 million which is equivalent to a loss of 78 residential homes (based on an
average assessment of $225,000). The City must be in a position to be both reactive
and proactive in dealing with this situation.
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Currently, the City is able to retain the education property taxes for Payment-in-Lieu
(PIL) properties. The education component as shown in Table One represents a
significant revenue gain for Pickering.
Table One
Breakdown of 2002 Property Tax Components
By Selected Property Classes
T ax Class City Education Region
% % %
Commercial 15.4 54.8 29.8
Industrial 16.2 52.4 31.4
Larç¡e Industrial 17.5 48.7 33.8
As the above table indicates, for commercial properties, the City, including the
education taxes will be able to retain over 70.2% of the property taxes. Obviously, it is
in the City's best interest to maximize its PIL revenues. The two roll numbers
specifically addressed in Recommendation 2 are PIL properties for taxation purposes.
Recommendation 2 will authorize the Treasurer to proceed to direct the firm of Poole
Milligan LLP to file a protective defensive appeal for the OPG property roll number 1801
020 06800 0000 for 2003 and to continue our investigative appeal for roll number 1801
020 022 09100 0000 located at 901 McKay Road. This Recommendation has been
reviewed with our lawyer Richard Poole who concurs.
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Confidential Report to Finance &
Operations Committee CS 18-03
Date: March 21,2003
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Subject: Filing of Assessment Appeals
Page 3
Recent Challenqes to Municipal Authority
During the last few years, municipalities have become more diligent and proactive
regarding the management of the property tax base as evident in Pickering's situation
with the OPG appeal. With the elimination of various Provincial grants, municipalities
have focused on maximizing their assessment tax base by filing assessment appeals.
Property tax agents are now throwing up "road blocks" questioning the authority of the
Treasurer of the local municipality to file assessment appeals. There is currently a
motion at the Assessment Review Board (ARB) to have the appeal dismissed because
the Treasurer filed the appeal without Council's specific authority. Regardless of the
outcome at the ARB, it is expected that the decision will be appealed to the Ontario
General Court. As a precautionary measure, our lawyer has advised us to have
Council approve Recommendations 2 and 3. Attachment 1 provides a brief explanation
of the current situation.
Investiqative Appeal- 901 McKay Road
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Attachment 2 provides a briefing note on the City's appeal of the property at 901 McKay
Road. As the briefing note indicates, the Region of Durham filed an assessment appeal
in 2001 trying to reduce the assessment of the Water Control Pollution Plant. After
hearing nothing from the Region, the City appealed the 2002 assessment to protect its
interests.
Current Status of the Appeal
The City has filed a Statement of Issues regarding the assessment deficiencies of the
plant. Based on the current information received from MPAC, it appears that the plant
is under assessed and expansions have not been included. Also, there is a water pipe
going from the plant into Lake Ontario that has not been assessed. From the City's
Planning Department, staff have learned that the water pipe is 1.1 kilometers in length
and 3050mm in diameter. It is staff's understanding that the construction cost of the
plant was well over $100 million but the facility's current assessment value is $34.3
million. (Any additional property tax revenue as a result of the appeal would be
applied to the 2004 or 2005 taxation year).
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The City has asked the Assessment Review Board to allow the City's property
assessment consultant to inspect the property to verify that all of the assessable items
have been recorded in the assessment records and that the values and property tax
classifications are correct. In other words, the City's approach and philosophy has
always been fair and equitable treatment of all taxpayers which includes the Region of
Durham. In fact our Statement of Issues has formally requested a "detailed inspection"
of the plant. On March 7, 2003, our lawyer wrote the City stating that the Region of
Durham is "vigorously opposed to the City's request for an inspection". On March 13,
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Confidential Report to Finance &
Operations Committee CS 18-03
Date: March 21,2003
Subject: Filing of Assessment Appeals
Page 4
2002 our lawyer received correspondence from the Region's Legal Counsel requesting
confirmation of our authority to file the assessment appeal.
Attachments:
1. Correspondence from AMTCO dated February 28, 2003 - Appeals to the ARB
2. Briefing note on Durham Water Control Pollution Plant
Prepared I Approved I Endorsed By:
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Gillis A. Paterson
Director, Corporate Services & Treasurer
GAP:vw
Attachments
Copy: Chief Administrative Officer
Recommended for the consideration of
Pickering City Counci
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ATTACHMENT#..L.TOREPORT# C!.5' /fj",o3
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To Educate and
Serve with Integrity
February 28, 2003
To:
Members of the Association of Municipal Tax Collectors of Ontario
From:
The AMTCO Board of Directors
Re:
Appeals to the Assessment Review Board, under the
Assessment Act
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It has come to our attention through various sources that a number of property
tax agents are requesting certain appeals, filed by municipalities, be dismissed
on the basis that staff did not have the authority to file the appeal. Specifically it
appears to be appeals signed by a staff member (Tax Collector, Assessment
Review Officer or Treasurer). The agents are stating that Council approval is
required on each and every appeal.
We understand that the ARB has heard one of these dismissal requests and a
decision has not yet been released.
The purpose of this memo is to simply make you aware of the situation, in light
of the approaching appeal deadline of March 31st.
It is the recommendation of the AMTCO Board that you consult with your
individual legal advisors concerning any changes you may want to consider in
this regard.
Should any further relevant information come our way, we will share it with you
as soon as possible.
Respectfu lIy,
grace L. :Mars/i
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Grace L. Marsh, President
Association of Municipal Tax Collectors of Ontario
ATTACHMENT #...2- TO REPORT#.li:../7-0J
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Briefing Note
Duffin Creek Water Pollution Control Plant (DCWPCP)
901 McKay Road
Roll Number 18 01 020 022 09100
Current Situation
. In 2001, (prior to March 31st) , the Region of Durham appealed the 2001
assessment of the DCWPCP stating that the assessment was too high.
(The DCWPCP is jointly owned by the Regions of York and Durham. Staff
are not aware of the ownership percentage between the two parties.)
. ONE YEAR LATER (March 28, 2002), after hearing nothing from the
Region, the City of Pickering filed a defensive assessment appeal for the
2002 taxation year. The appeal was filed in order to protect the City's
interests and options.
. It is staff's understanding that sometime after the City filed its appeal,
the Region of Durham withdrew its appeal of the plant. We are not
certain of time as we were not directly advised.
Backqround Information
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. The DCWPCP property is classified as a payment-in-lieu (PIL) for
taxation purposes. Therefore, the City retains the education portion of the
property taxes. For every dollar the City collects, the City retains $0.70
(based on 2002 tax rates.) Obviously, it is in the City's best interest to
maximize the property's assessment value because of the favorable tax
treatment to the City.
. During the OPG appeal, the City discovered that generally speaking, PIL
properties were not thoroughly assessed by MPAC. In other words, the
regular taxable properties are the top priority. As a matter of fact, the City
asked MPAC to conduct a thorough audit of the OPG Pickering facility and
their audit revealed that there were at least 12 buildings/structures that
were not assessed/missed. In addition, taxation staff have found several
errors on the assessment roll for the Federal Airport Lands
. The previous owner of this property was the Ontario Clean Water Agency
or OCWA. (OCWA is a Provincial Crown Agency.) As such municipalities
traditionally did not pay much attention to the assessment of Provincial
and Federal properties.
The Next Step
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. Pickering staff believe that based on MPAC's record on assessing PIL
properties and in-exercising financial due diligence, it would be prudent for
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the City to ensure that the property is fairly and accurately assessed. The
site inspection will determine if the property is properly assessed. The site
inspection involves doing an audit by comparing the existing
buildings/structures to MPAC's cost cards. In addition, the audit will also
ensure that the value as stated in MPAC's cost cards fairly represents an
accurate assessment value.
. Our experience of the OPG nuclear assessment appeal found that the
structure had been under assessed and or incorrectly assessed. Staff
believe that all property owners should be assessed properly to ensure
equity in the property taxation system.
. It is staff's understanding that the Municipality of Clarington is currently
dealing with an assessment appeal with St. Marys Cement and is trying to
have this property's assessment value increased. In addition, the City of
Oshawa has one staff person dedicated to assessment review and the
City is currently involved with the GM plant assessment appeal.
Analysis
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. The City of Pickering filed its appeal (one year later) after the Region of
Durham appealed this property's assessment value. Pickering staff felt
they had a duty and responsibility to protect the interests of the Pickering
taxpayers.
. The City of Pickering is currently in a limited growth scenario which has
reduced the positive benefits of assessment growth associated with
property taxation and therefore budgets. By pursuing property tax equity
(paying fair share of taxes) the City finds itself in an unique position of
increasing assessment where it is able to retain seventy cents for every
tax dollar billed. In other words, for every dollar increase in PIL
assessment - you would have to increase regular taxable
assessment by $4.61.
Another way to view the positive tax treatment is from the perspective of
budgetary tax levy. In order to offset a 1 % increase in the tax levy, the
City would require an increase in regular taxable assessment of $48.8
million. To generate the same amount of taxes, the City would only
require an increase in PIL assessment of $10.7 million.
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