Rules and Ancillary Document Review Checklist
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Document Reviewed   WAC 458-12-040

Title: Listing of property - Segregation of interests

Reviewer -  Jim Winterstein

Completed:  March 20, 1998
Date Review  Started:  March 3, 1998
Do not fill in this box

Is this document being reviewed at this time because of a taxpayer or business association
request? (If "YES", explain).   YES        NO   X.
If the answer is yes, provide the name of the taxpayer or business association. Also provide a brief explanation of the issues raised in the request.

Type an "x" (lowercase) in the column that most correctly answers the question, and provide clear, concise, and completed explanations where needed.


1. Explain the goal(s) and purpose(s) of the document:  This rule explains
   how the assessor and treasurer are to deal with a taxpayer request to
   segregate the taxpayer's interest from other co-owners of real property,
   to enable the taxpayer to pay property taxes on only his or her interest
   in the property.  The rule implements RCW 84.56.340.


2. Need:

   YES  NO
         x    If reviewing a rule are there any other ancillary documents that
              can be included in a rule revision? (List ancillary documents in
              the space provided).
        na    If reviewing an ETB or PTB or any other ancillary document can
              it be easily included in an existing rule?
    x         Is the document necessary to comply with the statutes that authorize it?
    x         Is the document obsolete to a degree that warrants repeal or revision?
    x         Have laws or other circumstances changed so that the document should be
              amended or repealed?
    x         Is the document necessary to protect or safeguard the health, welfare,
              or safety of Washington's citizens (welfare includes budget levels
              necessary to provide services to the citizens of the state of Washington)?
Please explain and list those ancillary documents recommended for repeal either because they should be incorporated into a revised rule or have outlived their usefulness. (An ancillary document is "an interpretive or policy statement that advise the public of the Department's opinions, approaches, or likely course of action." Ancillary documents do not have the same force of law as granted rules in the Administrative Procedures Act (Chapter 34.05 RCW). It includes documents such as Excise Tax Bulletins (ETB), Property Tax Bulletins (PTB), and Revenue Policy Memorandums (RPM). Court cases, Board of Tax Appeals (BTRA) decisions, Appeals Division decisions (WTD), Statutes (RCW) ARE NOT ancillary documents.): The rule needs to be revised to reflect statutory changes since it was adopted in 1968. The underlying statute was amended in 1994, 1996, and 1997 deleting some language and adding new language. Also, a new section (RCW 84.40.042) was passed in 1997 that affects how property segregations are treated in terms of valuation and payment of the taxes.

3. Effectiveness:



   YES  NO
         x    Is the document providing the results that it was originally
              designed to achieve in a reasonable manner?
         x    Are there regulatory alternatives or new technologies that could
              more effectively or efficiently achieve the same objectives?
Please explain answer(s): Although the rule is still of some use, the law which it implements has been changed since the rule was last revised, and the rule should be revised to reflect current law. Some counties are administering the law differently from others and the rule should provide clear guidance and interpretation of the intent and purpose of the statute.

4. Clarity:



   YES  NO
         x     Is the document written and organized in a clear and concise
               manner so that it can be readily understood by those to whom it
               applies? 
Please explain answer(s): The rule is badly in need of more precise wording and better organization.

5. Intent and Statutory Authority:



   YES  NO
    x          Is the document consistent with the legislative intent of the
               statutes that authorize it?
    x          Is the document based upon sufficient statutory authority?
         x     Is there a need to develop a more specific legislative
               authorization in order to protect the health, safety, and
               welfare of Washington's citizens?
         x     Is there a need to recommend legislative changes to the
               underlying statutes?.
List authorizing statutes, Give cites as required and explain answer(s): RCW 84.08.070 provides the Department with the statutory authority to adopt this rule.

6. Coordination: Agencies should consult with and coordinate with other
   jurisdictions that have similar regulatory requirements when it is likely that
   coordination can reduce duplication and inconsistency.

   YES  NO
         x     Could additional consultation and coordination with other
               governmental jurisdictions and state agencies with similar
               regulatory authority eliminate or reduce duplication and
               inconsistency?
Please explain answer: No other state agency deals with or supervises the administration of the property tax. In revising the rule, the Department will work with local officials who administer the tax in order to promote uniformity and consistency in the application of the rule.

7. Cost: (Answer yes only when a Cost Benefit Analysis was completed when
   the rule was last amended).

   YES  NO

         x     Have qualitative and quantitative benefits of the document been
               considered in relation to its costs?  (Consider only costs
               imposed by document not statute.)   
Please explain answer: This is an interpretive rule that imposes no new or additional administrative burdens on taxpayers or local government entitles that are not imposed by law. 8. Fairness:


   YES  NO
    x          Does the document result in equitable treatment of those
               required to comply with it?
    x          Should it be modified to eliminate or minimize any
               disproportionate impacts on the regulated community? (Consider
               only impacts imposed by document not statute).
         x     Should it be strengthened to provide additional protection?
Please explain answer(s): The rule needs to be more clearly stated and more precisely written. When the rule is revised, it will more clearly state what the statutory requirements are to ensure that those required to comply with it will be treated equitably.

9. LISTING OF DOCUMENTS REVIEWED: (Include any documents discussed
   above.  When listing statutes, ancillary documents, or other regulations also
   provide titles.  Court, Board of Tax Appeals (BTA), or Appeals Division (WTD)
   decisions should be listed by citation followed by a brief description (phrase
   or sentence) of the pertinent issue(s).)

Statute(s) Implemented: RCW 84.56.340  Payment on part of parcel or tract or
on undivided interest or fractional interest—Division—certification--Appeal

Court Cases: Olson v. Chapman, 4 W2d 522 (1940)

Ancillary documents: –––––

Administrative Decisions: –––––

Yes     No
         x 	Business Methods have substantially changed to warrant repealing
            or amending the document.

         x	Administrative  Changes have occurred enough to warrant
            repealing or amending the document.

10. Review Recommendation: Indicate whether you are recommending that the
    Department amend; repeal; or leave the rule or ancillary document as is.

    x	Amend

      Repeal

      Leave as is
      Incorporate ancillary document into a new or existing rule. (Subject
                of this review must an ancillary document and not a rule).

Explanation: (If you chose amend or a new rule,  please explain why rule
                 making is being considered and list specific reasons why the rule is
                 necessary.  If you choose "leave as is"  explain why rule should
                 remain in its present state.  Also explain any recommendation to
                 incorporate and/or repeal an ancillary document): This rule should
                 be revised to incorporate the provisions of chapter 301, Laws
                 of 1994, chapter 153, Laws of 1996, and chapter 393, Laws of
                 1997.  Some counties are administering the law differently
                 from others.  The information currently contained in this rule
                 needs to be rewritten to provide clearer guidance to these
                 local government officials.

 11. Manager action:     Date: ________________

_____	Reviewed recommendation         _____ Accepted recommendation

_____ Returned for further action

Comments: –––––

Review.doc last revised 1/28/98