Special Taxing Districts as Administrative (Municipal) Boundaries

Communities United States
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I’ve been meaning to post about this for a while, especially since I’ve noticed @ZeLonewolf has been re-tagging Census Designated Places (CDPs) and other locations in Maryland in an effort to streamline U.S. city tagging. I wanted to make sure that the handling of special taxing districts aligns within that framework.

Background: Special Taxing Districts in Maryland

In Maryland, we have a type of government entity called a special tax (or taxing) district. These exist in other states as well, and the U.S. Census Bureau tracks a variety of special districts across the country.

Many special districts are single-purpose entities, such as:

  • School districts
  • Water or sewer districts
  • Fiber-optic infrastructure districts
  • Land management districts

Since these serve specific functions rather than acting as broad local governments, they probably should not be mapped as administrative boundaries in OpenStreetMap. However, some special taxing districts in Montgomery County, Maryland, function similarly to municipalities, which raises the question of how they should be tagged.

The U.S. Census Bureau’s Classification

According to the U.S. Census Bureau, these special taxing districts are not classified as municipal corporations or governments. Instead, they are categorized as subordinate agencies and areas, the same designation given to entities like:

  • The Maryland Stadium Authority
  • The Seafood Marketing Authority

These districts do not function as full-fledged cities or towns but rather as limited-purpose local governance structures. This is important to consider when deciding how to map them in OpenStreetMap (US Census, Md. Gov’t Desc, p. 3).

Montgomery County’s Special Taxing Districts

Montgomery County has three special taxing districts that were created before the county had home rule (click each for the OSM entity):

These districts have a governing body (a citizen’s committee), levy property taxes, receive a share of county “piggyback” income taxes, receive state and county grants, and provide some municipal services (MC OLO 2008-5 , Ch. II, section F)

For revenue purposes, Montgomery County and the State of Maryland treat these districts as municipalities, grouping them with the county’s 19 incorporated municipalities.

Comparing Functions to Incorporated Municipalities

Montgomery County’s incorporated cities and towns, such as Gaithersburg, handle a full range of municipal functions, including:

  • Animal control
  • Building and code enforcement
  • Parking control
  • Parks and recreation
  • Police and fire services
  • Sewer, stormwater, and waste collection
  • Streets and sidewalks

The three special taxing districts offer more limited services:

  • Friendship Heights (a high-density urban area) provides fire services, health services, parks and recreation, police services, waste collection, streets and sidewalks, stormwater and sewer management, and building and code enforcement.
  • Drummond (a very small area) handles building and code enforcement and streets and sidewalks.
  • Oakmont only handles parking control, waste collection, and streets and sidewalks.

Some of these districts operate almost like municipalities, while others have minimal governance roles.

Should These Be Mapped as Administrative Boundaries?

The key question is whether these special taxing districts should be mapped as administrative boundaries in OpenStreetMap.

If so:

  • Should they be tagged as boundary=administrative?
  • What admin_level should they be?
    • admin_level=8 is typically used for municipalities.
    • Should they be treated the same way as a town or city, or should they have a different classification?

Since Montgomery County and the State treat them as municipalities for revenue purposes, it might make sense to classify them similarly in OSM. However, their governance powers are much more limited than a full municipality.

Would love to hear thoughts from the community. How are similar entities handled in other states?

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South Dakota has “Community Improvement Districts”: Relation: ‪Dakota Dunes‬ (‪17310253‬) | OpenStreetMap, Relation: ‪Powder House Pass‬ (‪17688353‬) | OpenStreetMap

These look like similar things to me, so I would map them like a municipality with a tag of border_type=special_taxing_district (or whatever else makes sense, I just made something up).

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I agree with SD_Mapman, I think it’s reasonable to map them as municipalities with admin boundaries, with a weird border_type. As a recent transplant to DC, thanks for the primer on what’s going on here. Montgomery County’s local government situation completely bewilders me.

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New Hampshire has “village districts”, which serve similar purposes (with the exception of schools, which have a different system). The districts have “all the powers in relation to the objects for which it was established that towns have or may have in relation to like objects, and all that are necessary for the accomplishment of its purposes.” This includes some required elected offices, an annual meeting, and the ability to levy taxes. Their boundaries may be contained within one town, cross into multiple towns, or extend into unincorporated areas, and they are independent of any town or city. I have not attempted to map them, as I have not been able to find a source for their boundaries outside of their incorporation documents, which can themselves be difficult to find.

In NH I would probably use border_type=village_district.

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As another data point, California also has a “municipality lite” concept called a community services district (CSD):

Fundamentally, these are not municipalities or general-purpose administrative units, but they have elected leaders and taxing authority and can mimic the scope of a municipality in terms of services provided:

Community services districts make up about 10 percent of the approximately 3,300 special districts in California. But special districts are allowed to perform only one specific service: water, fire protection, cemeteries, parks, and so on. The difference is that CSDs may perform any combination of multiple services—up to 32 in all, ranging from water and fire, to street lighting, sanitation, airport management, libraries, animal control and more.

However, I don’t think the number of services provided is a sound criterion for boundary=administrative in California, because CSDs fall on a spectrum:

Most CSDs, however, limit themselves to just a couple of functions. The Point Dume CSD in Los Angeles County manages a public park and a community center, as well as sponsoring various neighborhood recreation events. Christian Valley Park CSD in Placer County is limited to water delivery and road maintenance. On the other hand, the Bear Valley CSD in Kern County takes responsibility for water delivery, wastewater treatment, road and other infrastructure maintenance—even a police department.

Conversely, some bona fide incorporated cities are known as contract cities because they provide few or no services on their own, instead relying on the county to provide the usual services. Contract cities also fall on a spectrum. There isn’t an obvious point at which we can say a CSD has become administrative by providing enough services or a contract city has become non-administrative by providing too few. The level of service provision can change frequently based on procurement processes.

Instead, to the extent that we map CSDs, I’d suggest distinguishing them from incorporated municipalities, just as we currently distinguish other special districts and school districts. Instead of boundary=administrative, we need another boundary=* value, perhaps boundary=local_authority or boundary=services_district.

How does this relate to Montgomery County, Maryland? If these are just one-off quirks of history, if these would be cities but aren’t “for backwards compatibility” only, then sure, we can duck-tag them as boundary=administrative. Otherwise, I’d suggest some other kind of boundary=* so that data consumers have more opportunity to choose whether to distinguish these cases as necessary.

As a programmer, I’m familiar with the phenomenon that writing code comments is a good thing, but if you have to comment a single line of code with a 500-word explication, then something has gone wrong. Sometimes we wind up writing all that explication here on the forum, for the benefit of incredulous out-of-staters, but just make sure you can still justify a tagging choice more simply to someone who’s already quite familiar with the situation.

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