Statements of Issues, Evidence and Analysis

STATEMENTS OF ISSUES, EVIDENCE AND ANALYSIS

During appeal management, the Board may require the parties to complete written statements of issues, evidence, and analysis.

The purpose of a Statement of Issues, Evidence, and Analysis (SIEA) is to give the other party and the Board a clear sense of the issues, why a party takes a particular view of any issue and the requested disposition of the appeal.  If actual value or any component of actual value is in issue in the appeal, the parties are not required or expected to produce appraisal reports at this stage of the proceeding.  

Except for the details and particulars of a party’s issues in an appeal, the SIEA is without prejudice including the summary of evidence that may be relied on in support of a party’s position on each issue, the summary analysis of the evidence, the summary analysis of legal principles, if any, and the proposed recommendation for the amendment or confirmation of the roll.  The without prejudice summary of evidence may be in brief descriptive form and need not contain copies of actual evidentiary documents.

The SIEA must specify what the party is seeking in the appeal including a without prejudice recommendation for the amendment of the roll.  The purpose of the recommendation is not to provide an opinion of market value but to request a particular disposition the appeal.  The recommendation is without prejudice in that as the appeal proceeds the parties may change their recommendations.  The opinion of value eventually provided in an appraisal report produced for hearing may be different than the recommendation for the resolution of the appeal.

The SIEA is delivered to the other parties and the Board. When delivering to the other parties, the SIEA must include any documents relating to the property that are relevant to the appeal issues.  These documents do not have to be included if they have already been produced to the other party, if they originated with the other party, or if they are not in the party’s possession or control.  The Board only requires the SIEA (i.e. does not require copies of any documents at this stage of the appeal).

In certain cases it may be appropriate for the Board to treat the SIEAs as written submissions and make a decision on the appeal based on these statements. 

January 2021