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Friday, November 15, 2019

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FSA Submissions : FSA Final Submission on Draft Valuation Regulations

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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;
  • The 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.

Regarding 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.

Our 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.

Given 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)

Roger Godsmark
Operations Director
Forestry South Africa
Tel: +27 33 346 0344
Fax: +27 33 346 0399
Cell: 082 805 7123
E-mail: roger@forestrysouthafrica.co.za

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