5 July, 2017
FSA Final Submission on Draft Valuation Regulations
Please find attached
for your perusal our final submission to the Valuer General on the
Draft Valuation Regulations i.t.o. the Property Valuations Act.
We have huge concerns with these draft regulations - in brief these are as follows:
- The valuation methodology is based on a flawed "current use value" basis;
determination of value by adding the current use value and market value
together and then dividing by two is totally arbitrary;
- They will result in compensation payable being far from "fair and equitable"; and
- Are not consistent with the provisions of Section 25 of the Constitution or the PVA.
the third bullet point above, members need to be aware that the
compensation payable will be well below market value in terms of:
- Land - from 50% (if no net
profit is made at time of valuation) to 100% of market value
- Standing timber - 50% of standing value
- Moveable assets - 50% of market value
It goes without saying that the impact on the Industry would be huge if these Draft Regulations come into effect.
recommendation is that they be scrapped and re-drafted. What, however,
is of utmost concern is that the Draft Regulations seem to be a "done
deal". This is because the OVG has (a) already produced a Technical
Manual for use by valuers on how to interpret the Regulations and (b)
held training courses for all registered valuers on them.
the above, I believe that Organised Agriculture, including FSA, needs
to seriously consider Court action to interdict the VG from using them.
Download : Submission to The Valuer General - on the Draft Regulations in terms of The Property Valuations Act (Act 17 of 2014)
Forestry South Africa
Tel: +27 33 346 0344
Fax: +27 33 346 0399
Cell: 082 805 7123