Apollo Industries Pty Ltd v Chief Executive, Department of Lands [1993] QLC 68

LAND COURT, BRISBANE. 25th June, 1993. Re: Appeal against a decision of the Valuer-General Hervey Bay City Council - AV91-798 Apollo Industries Pty Ltd V. The Chief Executive, Department of Lands (Hearing at Noosa) DECISION Land described as Lots 3, 18-22 on Registered Plan 35184, (subsequently resurveyed as Lot 22 on Registered Plan 835509), Parish of Urangan, containing an area of 1. 732 hectares, situated at Torquay Road and Taylor Street, Pialba, is developed as a drive-in shopping centre (Bay Plaza - Woolworths). The land is zoned "Business". As at 31st March, 1990, the Valuer-General (as he then was) assessed the unimproved value of the land in the amount of $1,125,000. An objection lodged against that valuation was disallowed. It is against that decision which an appeal was filed in the Court. The appellant company estimated the unimproved value to be $350,000. The grounds of appeal are set out as follows:- " 1. That the valuation is unreasonable. 2. That the Valuer-General in arriving at the unimproved value of the land has not taken into account all factors affecting the land and the value thereof and in particular the valuation did not [1993] QLC 68 -- 1 of 20 -- take into account that a significant portion of the land was low lying and partially covered by a swamp which required substantial filling before the land could be utilised. 3. That if the value of the land has allegedly been or is to be determined by reference to or based on sales of land in the locality, all the circumstances affecting such sales should be admitted as evidence of value of the land or otherwise. 4. That the valuation has been made on the wrong basis in law." After adjournments, the matter eventually came before the Court for hearing on 28th May, 1993. Two witnesses, a civil engineer - Mr A.J. Mcvey, and a valuer - Mr C. Browning, were called by counsel for the appellant company. Mr G.E. Short, the valuer responsible for the valuation appealed against, gave evidence for the respondent. Mr Browning's valuation relied in part on Mr McVey's estimate of the cost of civil engineering works "required to bring the site from its naturally occurring condition to a condition that would be expected by an average buyer with the intent of developing a shopping centre site." In his considerations relevant to the original topography of the site, Mr McVey was guided by contour information available from sewerage design plans as well as photographs taken prior to filling. He identified two principal factors of influence being: " (i) The site was relatively "swampy" and contained poor quality, low bearing strength soils; and (ii) The lowest half of the site was subject to local flooding." The evidence is that the site was purchased by the appellant company in the late 1970's. Mr McVey had access to the results of the testing of soil samples taken from the site in 1978. Information obtained from the appellant company indicated that "the following works had been performed to bring the site to an -- 2 of 20 -- - Page 3 - acceptable condition for development of a shopping centre": " (a) Preliminary soil testing of on site material; (b) Stripping of vegetation; (c) Dewatering of depressed area; (d) Drainage catchments external to the site along the southern and eastern boundaries had to be piped through to the western boundary of the site; (e) Use of geofabric in soft areas to support construction equipment; (f) Importation of solid filling material; (g) Spreading and compacting of imported material; (h) Compaction testing of imported material; (i) Surveying and engineering control of the filling and drainage works. 0) Use of reinforced concrete as a paving material for carparks in lieu of gravel pavement with asphalt surfacing." Mr McVey had not been provided with the actual cost of development at the time it occurred, nor the quantities of fill involved. In his professional opinion, the works performed would have been necessary given the original characteristics of the site. He held the opinion that, in the absence of knowledge of quantities of actual work carried out it was possible to determine quantities with reasonable accuracy by "assessment of the 'as built' infrastructure and levels minus the pre-development infrastructure and level." He then proceeded to estimate the costs of the works at the date relevant to the valuation - 31st March, 1990 - as follows:- -- 3 of 20 -- Preliminary soil testing Stripping Vegetation Dewatering External Drainage catchments Geofabric - Page 4 - Importation of solid filling material (including $ 1,900 $ 5,120 $ 9,320 $ 24,100 $ 15,750 compaction) 15,090m3 @ $21. 77 /m3 $328,51 O Testing Filling $ 2,400 Concrete Carpark Slabs - increase above normal asphalt surfacing - ($311,010 - $134,080) $176,930 Surveying and Engineering Fees i 47,160 TOTAL VALUE OF WORKS $611,190 - - - - ---- Mr McVey gave evidence that his estimate of the cost of fill had been based on enquiries of a local quarry supplier and from his own local knowledge. The basis of the calculation was $6.50 per tonne of fill material delivered on site, before compaction. He said that fill material weighed about 1.8 tonnes per cubic metre in its loose state and about 2.35 tonnes per cubic metre compacted in place. The cost then equated $15.27 per cubic metre on a compacted volume basis. The cost of the compaction was estimated as $6.50 per cubic metre resulting in the adopted rate of $21. 77 per cubic metre to supply and compact the filling to a finished condition. The nature of the site was such that even after the filling as estimated, there remained a sub-surface drainage problem due to soft underlying soils and a high water-table fed by underground streams. He said that in such circumstances the carparking and driveway areas required concrete surfacing rather than the normal asphalt cement surface over a gravel base, otherwise the sub-surface saturation would cause constant maintenance and/or irreparable damage to the hardstand surfaces. Even with the concrete surface that had been laid, problems had -- 4 of 20 -- - Page 5 - occurred due to sub-surface saturation. He was able to confirm his opinion as to the necessity for this type of surfacing after considering the results of core sampling of the actual carparking area. The extra cost of the concreting was, in his opinion, a result of a natural disability of the site and a matter which a prudent developer, informed by soil testing, would need to consider before purchase and development of the site. To overcome the saturation problems, additional siteworks and further sub-surface drainage would have been necessary. In his opinion these works would have been more expensive than was the additional cost of concreting the carparking and driveway areas. Under cross-examination, Mr McVey was asked questions about the nearby Pialba Place (Coles) drive-in shopping centre site. He agreed that the contour plan he was shown indicated that the Coles site had originally been traversed by a drainage system and that it was reasonable to assume that it would have suffered some drainage and local flooding disabilities. He pointed out, however, that the Coles site was generally higher in elevation than was the subject, appeared to have been free draining and not affected by a depressed swampy area as was the subject. It was suggested to him that before development of the Coles site, it had been necessary for the developer to remove sub-surface coffee rock. He had no specific knowledge of the site development, but agreed that the presence of coffee rock, which he was surprised to hear, could have caused sub-surface drainage problems. This also would have been relevant to the type of hardstand development best suited to that site. To his knowledge, the Coles carparking area had been developed with an asphalt cement surface. Mr McVey held the opinion that when the need for dewatering of the -- 5 of 20 -- - Page 6 - depressed area on the subject land was considered, it was reasonable to envisage a six month period to bring the site from its unimproved state to a condition allowing structural development to proceed. He said that the actual use of geofabric was to strengthen the fill material and to support machinery during compaction of the fill. Alternatively more extensive excavation of soft material would have been necessary to provide a hard base. The cost of the additional excavation then replacement by imported fill material again would have been more expensive. His estimates included survey and engineering fees, because he felt the unimproved state of the site was such as to warrant professional engineering supervision. No allowance had been made for contingencies, although in his opinion it would not have been unreasonable to have done so. Turning now to the valuation evidence, it was Mr Browning's opinion that the land with siteworks effected, but with no remaining sub-surface drainage problem, would have possessed value equivalent to $70/m 2 or $1,213,000. He based this valuation on the evidence provided by five sales. The following comments are extracted from his tendered report under the heading of "Sales Evidence": " 1. Pialba Place Shopping Centre, vacant land component with an area of 2.0154 hectares was sold for $1,614,000 on the 27th February, 1987. This analyses at $80.08 per square metre. This site is considered superior to the subject because of Main Street frontage, better access and proximity to the town centre. 2. Vacant Land at Hunter Street, sold for $150,000 on the 23rd August, 1989. Described as Lot 2 on Registered Plan 68256 and having an area of 14 70 square metres. -- 6 of 20 -- - Page 7 - Sale analyses at $102 per square metre. The property is one removed from Torquay Road and has wide frontage to the street. A minimum of half this property is above the flood building line with the low land at the rear of the block providing parking. Considered superior to the subject on a per metre basis. The June 1989 quarter also marked the peak of the property boom in most areas of Queensland. Much smaller site than subject located between the subject and Pialba Place in superior position. 3. Vacant Lot at 54 Main Street, sold for $160,000 on the 24th July, 1989. Described as Lot 1 on RP 85251 having an area of 2023 square metres. Sale analyses at $79.09 per square metre. This property is in a prominent position with easy access and is considered superior to the subject. 4. House property at 16 Hunter Street, sold for $260,000 on 6th January, 1988. Described as Lot 2 on RP 85656 and having an area of 2557 square metres. Sale analyses at $101.68 per square metre. It was purchased by interests associated with the subject property, adjoins the subject property to the west and overlooks the Pialba Place property on the opposite site of Hunter Street. It is to the north of Sale 2 with Sale 5 in between these two sales. 5. House property at 12-14 Hunter Street, sold for $110,000 on the 23rd May, 1988. Described as Lot 1 on RP 65845 having an area of 1295 square metres. Sale analyses at $85 per square metre. It was also purchased by interests associated with the subject and similar remarks apply as to Sale of above." In assessing the site value as developed, Mr Browning commented that Taylor Street does not entice a significant volume of traffic, except that generated -- 7 of 20 -- - Page 8 - by the subject development. While Torquay Road is a busy thoroughfare, vehicular access to and from the subject property is restricted to Taylor Street. In his opinion, the subject property has inferior access and position to the Pialba Place shopping centre. It is the sale of the vacant land developed as the Pialba Place centre which he saw as the best available evidence of value, because the site was aggregated for development as a shopping centre. While the sale was "early in time" he expressed the opinion that values for sites of that nature had not changed significantly from the date of sale although there had been an upward movement in real estate values generally, peaking in mid 1989. In his opinion the subject land as developed was worth 30% less than the Pialba Place site as developed, but not on an unimproved basis. Evidence was given that the Valuer-General's unimproved valuation of Pialba Place as at the same relevant date equated $90/m 2• From an improved site value perspective, Mr Browning said that the actual construction of a concrete surfaced carparking area, provided no added value to the completed development over and above that which would have been added by an asphalt cement surfaced carpark. He saw the added cost of the necessary concrete construction as a site disability directly affecting the unimproved value of the land. He deduced the unimproved value from the following calculation: Improved Land Value - 17326 m2 @ $70/m2 Less - Value of land improvements $ 1,213,000 as per estimate from Engineers, Leddy Sergiacomi & Associates $. 611 ,000 -- 8 of 20 -- - Page 9 - Less - Administration Costs 3% of $611,000 Less - Interest on Cost for Half of 6 mths at 12% = $629,000 X 12 X .25 100 Less land clearing Less Land Tax and Council Rates calculated for 6 mths on $560,000 Land Tax $ 4,250 Rates $ 3,750 Less - Interest on Capital outlay for 6 mths = $552,000 X 12 X.5 112 $ 602,000 i 18,000 $ 584,000 i 19,000 $ 565,000 5,000 $ 560,000 8,000 $ 552,000 i 30,000 $ 522,000 Applied value: 17326 m 2 @ $30.12/m 2 $ 522,000 All calculations have been rounded." This then became the valuation for which the appellant company contended. Mr Browning saw the "administration costs" of a developer as adding to the actual cost of a development project, but it seems to me that any such expense is related to the cost of running a particular business. I see the apportionment of "administration costs" towards the added value of the site improvements as too narrow an interpretation of matters which reflect on the market value of the land. -- 9 of 20 -- - Page 10 - The exercise before the Court is to determine the unimproved value of the land in terms of the relevant legislation - the Valuation of Land Act 1944 (as amended). Unimproved value as defined, may well be, as suggested by Mr Browning, an artificial concept. Similarly, the definition of "the value of improvements" might not equate commercial concepts of value. For the purposes of the Act, however, the meaning of the latter term is found in section 12(2)(b): " 'The value of improvements' means, in relation to land, the added value which the improvements give to the land at the time as at which the value is required to be ascertained for the purposes of this Act, irrespective of the cost of improvements, .... Provided that the added value shall in no case exceed the amount that should reasonably be involved in effecting, at the time as at which the value is required to be ascertained for the purposes of this Act, improvements of a nature and efficiency equivalent to the existing improvements;" It has been accepted historically, that interest, even if notional, on monies outlaid, during a development period, is an expense reasonably involved in effecting improvements. I am not convinced that holding costs of land, such as the notional interest on the land content, or rates and taxes outlaid during the development period, fall within the statutory definition of value of improvements. Nevertheless, in conducting an exercise to assist in the assessment of unimproved value of land which required significant earthworks construction prior to development for its highest and best use, it would be impractical not to consider all costs which affect the worth of the land in its raw state. It seems to me then that Mr Browning's valuation approach should be seen in the context of a market orientated and practical exercise in considering the question of acceptable level of unimproved value, particularly in the absence of directly comparable sales -- 10 of 20 -- - Page 11 - evidence. If, on the other hand, the exercise was intended to reflect the statutory definition of firstly "improved value" then the "value of improvements", the question of whether the holding costs of the land (rates, taxes and interest on land) should be included in the exercise, would be another matter. I will accept Mr McVey's professional evidence that a prudent developer, fully informed as to the nature of the site once the earthworks were completed, would decide on the necessity for the hardstand areas to be concreted rather than asphalt sealed. I see the necessity however to deal with the additional cost aspect in a different manner to that which Mr Browning and Mr McVey have. That will become obvious later. Mr Short approached the valuation by three methods as follows: METHOD (A) Valuation by Direct Comparison. Standard Rate $80/m 2 Less $15/m 2 or 20% for filling/drainage works 17,320 m2 at $65/m2 = $1,125,800 ADOPT $1,125,000 METHOD (8) Valuation of Individual Sites Plus Balance Land · Lot 18 19 20 Area 2228m 2 2238m 2 2304m 2 Value $ 140,000 $ 155,000 $ 175,000 Rate/m 2 $63/m 2 $70/m 2 $76/m 2 -- 11 of 20 -- - Page 12 - 21 22 2350m 2 2352m 2 $ 190,000 $80/m 2 i 230,000 $98/m 2 $ 890,000 Plus Balance land at Rear Lot 3 5847m2 at $40/m 2 i 234;000 $ 1,124,000 ADOPT $1,125,000 METHOD (C) Valuation of Total Agg re gation Less Site Improvements 17 320m 2 at $80/m 2 Less Filling (1990 Cost) Compacted/Consolidated (to RL 12' contour) Trucked in Fill 1.332 ha at $10/m 3 = $133,200 x 1 m Av. Depth Cut and Fill at Rear 4000 m3 at $5/m3 = $ 20,000 $ 153,200 (1 /2 rate) Drains (1990 Cost) $ 15,200 $ 18,200 90m at $170/m run (750mm) 130m at $140/m run (600mm) 42m at $100/m run (450mm) ~ 4,200 i 37,700 Concrete Block Retaining Wall (1990 Cost) 100 m at $90/m run $ 9,000 (1.6 metres high) Railway Sleeper Wall (1990 Cost) Av. 1 metre high i 1.400 i 10,400 (35 metres at $40/metre run) $ 201,300 + 10% Contingencies i 20,130 $1,385,000 -- 12 of 20 -- - Page 13 - + interest on development costs for 1/2 development period of 6 months say 3 months at 13.5% + professional fees 8% ADOPT $1, 130,000 $ 221, 430 i 7,473 $ 228,903 i 18,312 i 247,215 $1,137,785 ====== In Mr Short's tendered report was a schedule of five sales, brief details of which are as follows: 1. Torquay Road, 2354m 2 site, zoned Residential B and Business, sold August, 1990 to show an analysed unimproved value of $77 per m2 , applied value $75 per m2 - subsequently developed as a medical centre. 2. Hunter Street, 1470 m 2 site, zoned Residential A (Business on Development Control Plan), sold August, 1989 to show an analysed unimproved value of $96 per m 2 , applied value $95 per m 2 - used for carparking purposes. This sale was Mr Browning's Sale 2. 3. Esplanade and Hillyard Street, 2023 m 2 site, zoned Residential B, sold September, 1990, to show an analysed unimproved value of $126 per m2 , applied $86 per m2 - subsequently developed as a Motel. 4. 77 Main Street, 1315 m 2 site, zoned Business, sold April, 1990, to show an analysed unimproved value of $101 per m 2 , applied value $90 per m 2 • 5. 174 Boat Harbour Drive, 3544 m 2 site, zoned Business, sold December, 1990 to show an analysed unimproved value of $80 per m2 , applied value $80 per m2 - subsequently developed as fast food outlet. As I understand his evidence, Mr Short arrived at the standard rate of -- 13 of 20 -- - Page 14 - $80/m 2 (before allowance for disabilities) in Method A, after consideration of the sales evidence provided, although that evidence was of greater assistance in establishing the values applied to the individual surveyed lots, in Method 8. There is no argument that !he highest and best use of the site is as developed, as a drive-in shopping centre. Although Mr Short appeared to take the greatest comfort from Method B, he agreed that if the highest and best use was for development in the smaller parcels, based on the evidence of sales of smaller parcels, then a discounting procedure would have been warranted, to establish the value of the aggregated parcel. The basis adopted in Method A (providing a disability (filling/drainage works) allowance of $15/m 2 overall) was checked by the development exercise carried out in Method C. Mr Short had calculated that the equivalent of 13,320m 3 of consolidated fill would be required. Mr McVey agreed that this estimate would be reasonable had there been no necessity to strip part of the site, remove unsuitable material from the depressed area then replace the removed material with imported fill. Mr Short allowed for the cut and fill and retention of part of the site which had actually taken place, while Mr McVey had not seen the need to consider those particular works as part of the site development. Mr Short's drainage estimate was based on an actual drainage plan which included collection and discharge of on-site stormwater. Mr McVey costed only the drains required for the siteworks development as indicated by the Council approval. In the end result, Mr Short has allowed for certain works which Mr McVey did not associate with the siteworks development. Mr Short also allowed for contingencies which Mr McVey did not, professional fees at 8% (Mr McVey 7.5%) and interest on the development costs at the rate of 13.5% (Mr Browning 12%) for half of the -- 14 of 20 -- - Page 15 - development period of 6 months. It can be seen that Mr Short did not set out to take an overly conservative approach to the development costs which he envisaged would be necessary. The major differences arise between the parties in the quantity and cost of imported fill and the various engineering related filling procedures seen as necessary by Mr McVey. The evidence with regard to the cost of supplying fill leaves much to be desired. It is obviously important in Mr Short's professional valuation duties, dealing with the question of unimproved value, to be well informed as to filling costs. He says his investigations in this regard extended to discussions with the Council engineer. His evidence is that by paying a royalty charge of $2.50 per cubic metre and cartage of $2 .50 per cubic metre, fill could be trucked to the site for a total of $5 per cubic metre. He then allowed $5 per cubic metre for costs associated with compaction. This resulted in his allowance for filling of $10 per cubic metre supplied and compacted. Mr McVey says he enquired of a local supplier (Baral) and was informed that the cost to supply fill of the quality used, at the relevant date, would have been $6.50 per tonne delivered. This he said, was in keeping with his local knowledge of the cost of supplying fill. On my calculations, using the evidence of Mr McVey that 1 cubic metre "loose" weighs 1.8 tonnes then his estimates are based on a delivered cost of $11. 70 per cubic metre as compared with Mr Short's $5 per cubic metre. The site was actually filled some 10 years earlier than the relevant date by the appellant company. Records as to the cost at that time and the source of supply were not made available to Mr McVey. The cost at that time is now irrelevant, yet the source of supply might have thrown some light on the subject. I am unable to reconcile the differences in the evidence -- 15 of 20 -- - Page 16 - and this aspect is critical to the valuation exercise. It seems to me however that if supplies of the significant quantity required for such development were readily available locally, as at the relevant date, on a royalty basis, as is suggested by Mr Short, then the cost allowed by Mr McVey on an overburden weight basis from the local quarry, seems to be excessive. In the absence of specific evidence as to the cost of an actual filling contract, I will increase Mr Short's allowance to provide some benefit of doubt in favour of the appellant. I propose to allow a cost to supply suitable fill material at the relevant date of $7.50 per cubic metre. The cost of compaction as provided by Mr McVey - $6.50 per cubic metre - will be adopted. It also appears to me that no allowance has been made by Mr Short for the increased "loose" volume required to allow for the compaction process. On the evidence given by Mr McVey as to the ratio between "loose" and "compacted", I will increase a rounded 15,000 m3 of compacted volume requirement to 19,500m3 of loose volume material. With regard to the evidence of value, Mr Short did not use the sale of the Pialba Place shopping centre site as did Mr Browning. While that sale was earlier in time, on a generally rising real estate market, the sale was not so distant as to be of no assistance in this matter when the paucity of evidence is considered. Mr Short was obviously aware of the critical details of the sale as it seems that he has considered the evidence relevant at an earlier time. He said that the Pialba Place site was also affected by natural disabilities related to the need for removal of unsuitable natural material (coffee rock), importation of fill and drainage works. It is seen as unfortunate that an analysis of that sale on a like with like development basis, did not form part of Mr Short's primary evidence. He agreed that before a -- 16 of 20 -- .. . - Page 17 - proper comparison could be made between the two shopping centre sites, the degree of disability of the Pialba Place site would need to be known. Mr Browning accepted the sale for what is was, an acquisition of the site for development of a shopping centre, showing a land content of about $80/m 2 three years prior to the relevant date. His verbal comparison is limited to a 30% degree of inferiority attaching to the subject site if it was able to be compared on a "like with like" development basis, but Mr Browning had apparently made no enquiries as to the degree of siteworks necessary before development of the Pialba Place shopping centre took place. I am unable to gain any real assistance from the Pialba Place site sale or relativity comparisons provided by the valuers, in the absence of cogent details as to the cost of siteworks development of the site. It is noted however, that the price paid for the aggregated site was generally within the range of values shown by the later sales of the smaller "Business" sites. It seems then, that rather than any discounting taking place on a pro rata area basis, that larger site with potential for drive-in shopping centre development, commanded a level of value generally comparable to that paid for the much smaller "Business" zoned sites, later in time and on a rising market. The sales evidence is admittedly weak, when are considered the questions of size, zoning and development potential, location and siteworks development required on the sale properties and then the adjoining owner relationship involved in Mr Browning's Sales 4 and 5. Nevertheless, and particularly in the absence of details of the site development costs involved in the Pialba Place sale, I am unable to find that Mr Short's standard rate of $80/m 2 has been proved wrong. -- 17 of 20 -- ' . ' - Page 18 - However, and as referred to earlier, it seems to me that the starting point, or standard rate needs to be considered in light of the cost of additional works involved in concreting the hardstand areas. This work would take place at a later time in the actual shopping centre development. Mr McVey's evidence is that the additional cost would be $176,930. While engineering fees would add to that amount, it is seen that some saving in the volume of fill might have resulted from the sand under-fill to the concreting procedure. In addressing the question of sub- surface drainage disability, in the broader valuation terms that reflect market conditions, I will adopt a rounded value of $70/m 2 for the site as filled, on the basis that a developer would then need to consider the disability known to exist at that stage of development. Although I am not fully informed as to some holding costs (rates and taxes) which would be involved I would approach the notional development valuation exercise as follows:- Land, with siteworks completed, but with sub-surface drainage disability: 17,320 m2 @ $70/m2 Less Estimated Costs of Development: Preliminary soil testing Stripping vegetation (to including clearing) Dewatering Drainage Geofabric Filling: 19,500 m 3 loose fill supplied @ $7.50/m 3 = $ 146,250 Spreading, compacting and trimming $ 1,900 $ 5,120 $ 9,320 $ 24,100 $ 15,750 15,000 m3 @ $6.50/m3 = $. 97,500 $243,750 $ 1,212,400 -- 18 of 20 -- Fill testing Survey fees - Page 19 - Engineering fees 7.5% of $302,340 $ 2,400 $ 5,000 i 22,675 $330,015 Interest 13.5% for 3 mths (half estimated development period) say i 11,140 i 341 ,155 $ 871,245 Less Holding charges Rates and Taxes - say $ 12,500 Interest on net land value 13.5% for 6 mths i 54,275 i 66,775 Net Land Value $ 804,470 Conclusion: The preceding exercise is one which I see as being of assistance in understanding the significance which estimated development costs would have on the value of the land if it was, as it has to be, considered in its unimproved state. It is well known that the real estate market is not controlled by precise estimations or calculations. Valuations need to reflect the negotiation processes and rounding processes which take place between willing, not over-anxious and prudent parties. The subject land in its unimproved state had major problems - and problems which would hand to any potential purchaser a negotiating advantage. On the evidence before the, the cost of development is clouded by the widely different estimates of the cost of importation of fill. see the need to take a final conservative view, again providing benefit of doubt in favour of the appellant. I will adopt a value based on $45/m 2 with the amount of the valuation then rounded to $780,000. -- 19 of 20 -- ' - Page 20 - Finding The appeal is allowed, the Valuer-General's valuation set aside and the unimproved value determined in the amount of $780,000. (R. E. Wenck) Member of the Land Court. -- 20 of 20 --