Does the Application of Epr Instead of Steb Ratio Violate Principles of Uniformity and Equal Protection of Taxpayers ?

In Armco, Inc., 100 Pa. Commw. 452, 515 A.2d 326 (Pa. Cmwlth. 1986), because the established predetermined ratio (EPR) varied more than 15% from the State Tax Equalization Board (STEB) ratio, the trial court was required to apply the STEB ratio to obtain a uniform assessed value. Because Armco requires application of the STEB ratio to ensure the uniformity of assessed values and because the STEB ratio was not applied in this case, I would conclude that the reassessment of Taxpayers' Property on appeal is in violation of the constitutional requirement for tax uniformity. In Downingtown Area School District v. Chester County Board of Assessment Appeals, 819 A.2d 615 (Pa. Cmwlth. 2003), appeal granted in part, 577 Pa. 420, 846 A.2d 74 (2004), the trial court assessed the taxpayer's property using the EPR of 100% instead of the STEB ratios of 89.8% and 85.2%. The taxpayer argued that the application of the EPR instead of the STEB ratio violated principles of uniformity and equal protection. This court held only that the application of the EPR complied with the statute because it varied from the STEB ratio by less than 15%. This court did not specifically examine whether the 15% variation allowed by the statute satisfies the constitutional requirement for tax uniformity.