Tribunals Ontario
Tribunaux décisionnels Ontario
Assessment Review Board
Commission de révision de l’évaluation foncière
ISSUE DATE:
March 16, 2021
FILE NO.:
WR 168492
Assessed Person(s):
Lloyd Reynolds Lee and Fern Elaine Lee
Appellant(s):
Lloyd Reynolds Lee and Fern Elaine Lee
Respondent(s):
Municipal Property Assessment Corporation Region 05
Respondent(s):
Township of Central Frontenac
Property Location(s):
CON 1 W ½ LOT 19 RP
Municipality(ies):
Township of Central Frontenac
Roll Number(s):
1039-040-020-00700-0000
Appeal Number(s):
3381687 and 3397781
Taxation Year(s):
2019 and 2020
Hearing Event No.:
738688
Legislative Authority:
Section 40 of the Assessment Act, R.S.O. 1990, c. A.31
APPEARANCES:
Parties
Representative
Lloyd Reynolds Lee and Fern Elaine Lee
Lloyd Reynolds Lee
Municipal Property Assessment Corporation
Kalin Doucet
Township of Central Frontenac
No one appeared
HEARD:
January 11, 2021 by telephone conference call
ADJUDICATOR(S):
Subuola Awoleri, Member
DECISION
OVERVIEW
1Lloyd Reynolds Lee and Fern Elaine Lee (the “Appellants”), the owners of CON 1 W ½ LOT 19 RP (the “Subject Property”), appealed the 2019 assessment of the Subject Property to the Assessment Review Board (the “Board”) under s. 40 of the Assessment Act, R.S.O. 1990, c. A.31 (the “Act”) on the grounds that the assessment is too high.
2For the 2019 and 2020 taxation years, the current value assessment (“CVA”) was returned at $40,500. The Municipal Property Assessment Corporation (“MPAC”), provided the Board with an opinion of value for the Subject Property at $33,500 and requests that the Board accepts this amount as the CVA of the Subject Property for the 2019 and 2020 taxation years.
3Lloyd Lee argued that the current value of the Subject Property should not be more than $10,000 and added that he would not purchase it for this amount due to its condition. While MPAC’s opinion of value is based on comparisons with the soil quality of other properties, the Appellants argue that other features should also be taken into account, most importantly, the limited access to the property.
4Section 40(26) of the Act provides that “… an appellant shall be deemed to have brought the same appeal in respect of a property…if the appeal is not finally disposed of by March 31 of the subsequent taxation year....”. The Appellants are deemed to have brought the same appeal in respect of the 2020 taxation year.
5At the completion of the hearing, the Board reserved its decision.
Issues for the Hearing
6The issues to be determined are:
What is the correct current value of the Subject Property for the 2019 and 2020 taxation years?
Is the current value as determined by the Board equitable in reference to the assessments of similar lands in the vicinity?
Result
7The Board determines the correct current value of the Subject Property to be $6,062 (rounded).
8The Board finds that there is no evidence to support a conclusion that the Subject Property requires a reduction in its determined current value in order to make it equitable with the assessment of similar properties in the vicinity.
9The Board reduces the assessment of the Subject Property from $40,500 to $6,062 for the 2019 and 2020 taxation years.
ANALYSIS
Description of the Subject Property
10The Subject Property is vacant land used for farming purposes, in the farm property class, without any building or structure, located in the Township of Central Frontenac. It has only a summer seasonal access on its west side. There is no structure or hydro on the Subject Property. It has a small stream or creek on its east side. It has a total site area of 80.52 acres, with soil class 6, which is the worst and least desirable soil class for soil productivity. The characteristics of this soil class is swampy, hill, rocky and treed.
Issue 1 - What is the correct current value of the Subject Property for the 2019 and 2020 taxation years?
11In accordance with s. 44(3)(a) of the Act, the first mandate of the Board is to determine “the current value of the land”. The Board must determine what the Subject Property would have sold for in an arm’s length transaction on the January 1, 2016 valuation day set by the Act.
12The Board finds that the current value of the Subject Property for the 2019 and 2020 taxation years to be $6,062 (rounded).
MPAC’s Proposed Comparable Property Sales
13The Board finds that MPAC’s proposed comparable property sales are all superior to the Subject Property and therefore not comparable to the Subject Property.
14MPAC presented the Board with five proposed comparable property sales. Kalin Doucet, MPAC’s representative testified that these sales are all farm land sales and are comparable to the Subject Property. The details of these property sales are attached to this Decision.
15Mr. Doucet testified that he used digital imagery technique to determine that the Subject Property has 23 acres of hard land, which he testified as being viable for farming operation, while the remaining 57 acres is mostly swampy land. Consequently, he added that MPAC only assessed the Subject Property using the 23 acres of hard land, which upon a Request for Reconsideration by the Appellants was determined to have soil class 5. He further testified that MPAC’s proposed comparable property sales have site areas that ranged from 11 to 18 acres with soil class 4 or 5, which make these property sales similar to the Subject Property’s 23 acres of hard land.
16Mr. Lee testified that none of MPAC’s proposed comparable property sales are comparable to the Subject Property. He submitted that the only comparable feature is their classification as farm properties.
17During cross-examination, Mr. Doucet admitted that he did not inspect the Subject Property and or any of the properties used for MPAC’s proposed comparable property sales. Mr. Doucet advised the Board that due to the COVID-19 pandemic he was unable to carry out the inspection. He testified that he viewed the Subject Property by digital imagery, reviewed the soil classes and farm land classification and he believed the information he obtained was accurate. The Appellants testified that the appeal commenced before the COVID-19 pandemic and MPAC should have conducted an on-site inspection of the Subject Property and its proposed comparable properties.
18The Board notes that the commencement date set by the Board for this appeal was October 7, 2019. MPAC’s valuation report is dated November 1, 2019, which is prior to the emergence of the COVID-19 pandemic. MPAC should have conducted an on-site inspection of the Subject Property, especially when it was aware, through various discussions with Mr. Lee and Mr. Lee’s email dated November 3, 2019 to Mr. Doucet that the Appellants’ main issue in this appeal is access to the Subject Property.
Access to the Properties (Summer Seasonal)
19MPAC’s proposed comparable property sales all have year-round access, whereas the Subject Property can only be accessed by a summer seasonal trail. Mr. Lee testified that the reason they purchased the Subject Property from the previous owner, was because they owned the adjoining property and the previous owner used to illegally access the Subject Property using their adjoining property. He also added that the Subject Property does not have a legal access and can only be accessed from a Township trail. Further, from this trail, access to hard land on the Subject Property can only be made by crossing on ice if the swamp is completely frozen such that it can hold body weight or by using chest waders in open water.
20Mr. Doucet testified that MPAC does not assess farm properties based on its accessibility but rather only based on soil productivity.
21The state and condition of a property may have an impact on the current value of the property. See Municipal Property Assessment Corporation, Region No. 16 v. Melnikova, 2017 CanLII 81711 (ON ARB) at paragraph 6.
22Section 1 of the Act defines current value as “the amount of money the fee simple, if unencumbered, would realize if sold at arm’s length by a willing seller to a willing buyer”. That is, what would a willing buyer pay a willing seller for the Subject Property if it sold on January 1, 2016.
23The time adjusted sale prices of all MPAC’s proposed comparable property sales with year-round access range from $32,306 to $81,904. Mr. Lee testified that the east and west side of the Subject Property, which they do not own, came up for sale as tax sales. He added that these properties are mostly swampy with no access. He further testified that the east side sold for $6,700 and the only offer received for the west side was abandoned by the purchaser who probably forfeited the down payment after a proper view of the property. He submitted that they did not purchase these properties because they did not believe they were worth the purchase price. The Board did not place any weight on this sale in determining the current value of the Subject Property as Mr. Lee testified that it was a tax sale. However, on the balance of probabilities, a willing buyer will not pay the same amount for the Subject Property with only summer seasonal access compared to a farm property with year-round access. This feature would be accounted for in the purchase price.
24MPAC provided in its valuation report that “accounting for only 23 acres of land addresses many of the owner’s complaints about access and swamp lands, and the determined market value is well below similar sized properties which also have issues of swamp and usable lands”. MPAC acknowledged the Appellants’ issue regarding access to the Subject Property. MPAC cannot substitute the issue of summer seasonal access to the Subject Property for a reduction in the size of the land, since a willing buyer would purchase the whole Subject Property comprising of 80.52 acres, with the knowledge of its limited access.
25Mr. Lee testified that he had visited four out of five of MPAC’s proposed comparable properties and he is familiar with these properties. He provided the Board with detailed comparisons between MPAC’s proposed comparable properties and the Subject Property. He submitted that this will provide the Board with insight on the differences, since MPAC did not provide aerial photographs of these properties for the Board to view the differences between them and the Subject Property. MPAC did not object to Mr. Lee’s testimony.
Sale 1
26In addition to having year-round access, this property has a silo, built in 1903, a shed, built in 1930 with building total area of 277 square feet (“sq. ft.”) and a type one barn built in 1900 with building total area of 2,235 sq. ft. Hydro is also available on this property. The Subject Property does not have these features. This property has 17.14 acres of class 4 soil, a better soil class than even the 23-acre hard land portion of the Subject Property and 31.36 acres of class 6 soil. It sold in April 2015 for $30,000 for a time adjusted sale price of $32,306. Mr. Lee testified that since the sale of this property, it has been severed into two properties and a house has been built on its north-west side. The Board finds Mr. Lee’s testimony credible, since he testified that he had visited this property and is also familiar with it. This property sale has the lowest sale price of all MPAC’s proposed comparable property sales, and has superior features as compared to the Subject Property. The Subject Property’s current value on a balance of probabilities should be lower than the time adjusted sale price of this sale. The Board determines that this proposed comparable property sale is superior to the Subject Property, due to year-round access, soil quality, and existing structures.
Sale 2
27This property was sold as vacant residential/commercial/industrial land owned by a non-farmer, with a portion being farmed. In addition to having year-round access, it also has hydro available on it. This property has 11 acres of soil class 4, a better soil class than the hard land portion of the Subject Property and 24.55 acres of soil class 6. It sold in April 2015 for $37,000 for a time adjusted sale price of $39,844. Mr. Lee testified that this property is owned by his father-in-law and he is familiar with it. He added that this property can be severed, it recently sold, and the purchasers are planning to erect a building on it. He testified that the Subject Property cannot be severed, and no building can be built on it, due to its marsh and swampy land. The Board finds that these features make this property superior to the Subject Property because, of its year-round access, severability, hydro availability, soil quality and ability to construct a building on it.
Sale 3
28Mr. Doucet testified that this sale is the most similar to the Subject Property, in terms of soil class, area and location. He also added that this sale and the Subject Property both have swampy land. The Board notes that Mr. Doucet admitted that he did not inspect this property. This property was sold in March 2016 for $50,000 for a time adjusted sale price of $48,971. In addition to its year-round access, hydro is available on this property. It has less swampy area of 26% - 50%. The Subject Property has more swampy area of 51% - 75%. This property has 18 acres of soil class 5 and 12.42 acres of soil class 6. Mr. Lee testified that he is also familiar with this property. He further testified that it has complete road access on two of its four sides and since its sale, a house has been built on it. The Board determines that this property is superior to the Subject Property due to its year-round access, hydro availability, and has less swampy land than the Subject Property.
Sale 4
29In addition to its year-round access, this property has hydro available on it. It has 13.22 acres of soil class 4, a better soil class than the hard land portion of the Subject Property and 43 acres of soil class 6. This property sold in May 2016 for $85,000 for a time adjusted sale price of $81,904. Mr. Lee testified that he is also familiar with this property. He added that it has Township roads on two sides, it can be severed and there is a house being built on it. He testified that the Subject Property does not enjoy these features. The Board finds that this property is superior to the Subject Property due to year-round accessibility, soil quality, severability, hydro availability, and ability to construct a house.
Sale 5
30In addition to its year-round access, this property has a gravel road. Although this property has no hydro available on it, it has one acre of soil class 2 and 3 acres of soil class 4, both of which are better soil classes than the hard land portion of the Subject Property, and 23.57 acres of soil class 6. It sold in April 2016 for $72,000 for a time adjusted sale price of $69,943. Mr. Lee testified that this is the only property he did not visit. The Board finds that the year-round access, gravel road and soil quality make this property superior to the Subject Property.
Appellants’ Proposed Comparable Property Sales
31The Board finds that the best evidence to determine the correct current value of the Subject Property is the Appellants’ proposed comparable property Sale 2.
32The Appellants presented as evidence a Letter of Opinion about the Subject Property, dated December 22, 2019 from Bob Bertrim, a real estate agent. Mr. Bertrim stated in this letter that “as a real estate agent I would not be interested in listing such a property as the access is very seasonal and it has such limited uses. It is my opinion that the subject property would only be of use to a neighbouring landowner”. Mr. Bertrim attached three proposed comparable property sales to this letter. Mr. Lee advised the Board that Mr. Bertrim was not present at the hearing. He testified that after 38 years as a realtor, Mr. Bertrim had retired.
33Mr. Doucet advised the Board that Mr. Bertrim should have been available at the hearing for cross-examination. However, MPAC presented as part of its evidence, property and sales information on the Appellants’ proposed comparable property sales, for review by the Board.
34During cross-examination, Mr. Lee admitted that he was not aware that the comparable property Sale 1 had 1.83 acres of waterfront cottage situated on it and it was not a farm property. He also admitted that he was not aware that the proposed comparable property Sale 3 was not an arm’s length sale. Mr. Doucet advised the Board that it was a sale by a joint tenant re-distributing the percentages in the property. Mr. Doucet added that it was a sale of a 25% share of the property. The Board finds that the Appellants’ proposed comparable property Sales 1 and 3 are not comparable to the Subject Property.
35According to MPAC’s property and sales information, comparable property Sale 2 sold in June 2019, for $5,000, for a time adjusted sale price of $3,764. This property has the same property code 200 as the Subject Property described as a farm property without any buildings or structures. The actual site area is 50 acres. It has no access and there is no hydro available on it. These features are similar to the Subject Property although the Subject Property has a larger site area of 80.52 acres, of which Mr. Doucet testified 23 acres is hard land. Mr. Lee testified that this property is comparable to the Subject Property due to the similarity of the features situated on it.
36Mr. Doucet argued that there is no indication that the Appellants’ property Sale 2 was listed in open market and it does not meet the definition of an arm’s length sale. During cross-examination, Mr. Doucet questioned Mr. Lee about the validity of this sale. Mr. Lee confirmed that it was a valid sale and that even though the seller and buyer knew each other, it was sold by a willing seller to a willing buyer for $5,000. Mr. Lee further added that he was not aware if it was listed in the open market. MPAC provided details of Sales 1 and 3 but did not present the Board with any evidence that Sale 2 was not an arm’s length sale or that the seller and the buyer were not willing parties to the sale transaction. Mr. Lee did not state that the parties to the sale transaction were related, he only testified that they knew each other. There was no evidence before the Board that the seller and buyer were coerced into this sale transaction.
37In 1906661 Ontario Inc v Municipal Property Assessment Corporation Region 15, 2015 CanLII 66513 (ON ARB), (“1906661 Ontario Inc.”), part of the issue the Board had to determine was whether the sale of the subject property took place between unrelated parties. The Board determined that:
The sale took place between a seller and a buyer who were dealing at arm's length. The argument advanced by MPAC that because the parties knew each other, they were not dealing at arm's length is an incorrect assumption. It is the Board's view that a business relationship per se, does not necessarily change a buyer's goal to obtain the lowest price and a seller's goal to obtain the highest price possible. To conclude otherwise, would infer that one of the parties to the transaction is willing to subsidize the other. No evidence was presented by the assessor to support a finding that there was some form of collusion between the buyer and seller for abdicating their inherent financial interests in the transaction.
38The Board in 1906661 Ontario Inc., further determined that the private sale was an arm’s length sale between a willing seller and a willing buyer. The Board agreed with the decision in Toronto (City) v. Municipal Property Assessment Corporation, Region No. 9, [2013] O.A.R.B.D. No. 11, (“Toronto City”) where the Board determined that exposure to open market is not the legal test. The Board determined at paragraph 26 that:
Key in the Act's definition is the notion of an arm's length transaction between a willing seller and a willing buyer. While exposure on the open market is a good indicator that these two ingredients are present in the transaction, it is not part of the legal test.
39There was no evidence before the Board to question the validity of the Appellants’ proposed comparable property Sale 2. In Toronto City, the Board found at paragraph 26 that “it does not agree with the proposition that a sale is invalid unless proven otherwise”. The Board finds on the balance of probabilities, in accordance with s. 1 of the Act, that the Appellants’ proposed comparable Sale 2 is a valid sale, as the only evidence on this point was that the sale was not made on the open market and that the buyer and seller knew each other, which do not establish that a sale is not arm’s length.
40MPAC also argued that the sale of the Appellants’ proposed comparable property Sale 2 is an outlier. In support of that argument, and to test its opinion of value for the Subject Property at $33,500, MPAC presented the Board with 12 sales of vacant residential land. Mr. Doucet testified that although he believes that the highest and best use of the Subject Property is farm land, he considered the Subject Property selling as a vacant recreational or residential land, and he used the property sales of 12 vacant residential land not on water to determine what the Subject Property may sell for. Only 2 of these vacant residential sales don’t have year-round access. MPAC argued that the Appellants’ proposed comparable property Sale 2 is an outlier and it does not fall in line with property sales 11 and 12 of the vacant residential land that have no access. These sales both sold in 2015 for time adjusted sale prices of $36,051 and $21,097 respectively.
41The Board asked Mr. Doucet why he used the sales of vacant residential properties to test MPAC’s opinion of value. He advised that he was assuming that the Subject Property may sell as vacant recreational or residential land and it depends on the intention of the purchasers. The Board finds this speculative. In order to determine the most profitable use of the Subject Property, evidence must be adduced to show that the probable use is physically possible, legally permissible, financially feasible and maximally productive. This is a valuation principle known as highest and best use. See General Motors of Canada Ltd. v. Municipal Property Assessment Corp., Region No. 27, [2017] O.A.R.B.D. No. 13, at paragraph 15 and 17, where the Board stated that “for assessment purposes the highest and best use of a property is tied to its state and condition”. MPAC did not adduce evidence of the probable use of the Subject Property. Besides, MPAC did not dispute the highest and best use of the Subject Property as farmland. Accordingly, the sales of vacant residential properties presented by MPAC are not of assistance in determining the current value of the Subject Property.
Findings on Issue 1 - Current Value
42The Appellants’ proposed comparable Sale 2 sold in June 2019 for $5,000. This sale is far removed from the valuation date of January 1, 2016. The practice of the Board is to use comparable property sales that sold between 12 to 18 months on either side of the valuation date. However, MPAC provided the time adjusted sale price as $3,764 and the Board finds that this is the best evidence to determine the current value of the Subject Property. The actual site area is 50 acres. There was nothing in evidence regarding the soil quality of the entire 50 acres of land. The time adjusted sale price per acre is $75.28, when applied to the total site area of the Subject Property of 80.52 acres, provides a value of $6,061.54.
43Mr. Lee testified that in 2020, they purchased the East half of the Subject Property of 75 acres for $5,000. This part is adjacent to the Subject Property. He added that this property is land locked, with no legal access, only accessible by a canoe. He further testified that this purchase was not through a realtor, but it was an arm’s length sale by a willing seller to a willing buyer. He submitted that the fact that they knew the seller does not make the sale an invalid sale. The Appellants and the seller were not related. This sale is similar with the Appellants’ comparable property Sale 2, in terms of the condition of the property with no access and size. The Board places less weight on this sale to determine the current value of the Subject Property as it is too far removed from the valuation date and the Appellants did not provide the time adjusted sale price for this sale. However, this sale reveals what properties with no access are selling for within the vicinity. Consequently, on the balance of probabilities, the Board finds that the current value of the Subject Property to be $6,062 (rounded) for the 2019 and 2020 taxation years.
Issue 2 - Whether there should be an equitable reduction of the current value pursuant to [s. 44(3)](https://www.canlii.org/en/on/laws/stat/rso-1990-c-a31/latest/rso-1990-c-a31.html#sec44subsec3_smooth)(b) of the [Act](https://www.canlii.org/en/on/laws/stat/rso-1990-c-a31/latest/rso-1990-c-a31.html), and, if so, what the amount of this reduction should be.
44Section 44(3)(b) of the Act directs that after determining current value, the Board shall have reference to the value at which similar lands in the vicinity are assessed and “adjust the assessment of the land to make it equitable with that of similar lands in the vicinity if such an adjustment would result in a reduction of the assessment of the land”.
45The Appellants did not raise equity as an issue and did not present any evidence on the appropriate reduction based on equity.
Findings on Issue 2 - Equity
46The Board finds that there is no evidence provided by the parties to support a reduction in the current value of the Subject Property, in order to make it equitable with the assessment of similar properties in the vicinity.
CONCLUSION
47The Board determines that the current value of the Subject Property is $6,062 (rounded) with no adjustment for equity.
ORDER
48The Board orders that the assessment of the Subject Property is reduced from $40,500 to $6,062(rounded) for the 2019 and 2020 taxation years.
"Subuola Awoleri"
SUBUOLA AWOLERI
MEMBER
Assessment Review Board
Website: www.tribunalsontario.ca/arb
Telephone: 416-212-6349 Toll Free: 1-866-448-2248
Subject Property
Property #1
Property #2
Property #3
Property #4
Property #5
Roll Number
103904002000700
103904001002900
103904001002908
103907002017700
103904002025500
103901003003325
Address
0
1083 HOOVER LANE
HOOVER LANE
1027A BENDER RD
1858 WAGARVILLE RD
1099 HAYES RD
Neighbourhood
F021 – 501
F021 – 501
F021 – 501
F021 - 501
F021 - 501
F021 - 501
Property Code & Desc.
(200) Farm Property Without Any Buildings/Structures
(210) Farm Without Residence - With Secondary Structures; With Farm Outbuildings
(260) Vacant Residential/Commercial/ Industrial Land Owned By A Non-Farmer With A Portion Being Farmed
(200) Farm Property Without Any Buildings/Structures
(200) Farm Property Without Any Buildings/Structures
(200) Farm Property Without Any Buildings/Structures
Distance in km
2.7409
2.6372
11.7923
7.8161
27.4074
Valuation
Current Value Assessment
$40,500
$56,000
$14,200
$21,500
$35,500
$18,200
Sale
Sale Date
20150416
20150416
20160301
20160531
20160401
Sale Amount
$30,000
$37,000
$50,000
$85,000
$72,000
Time Adjusted Sale Amount
$32,306
$39,844
$48,971
$81,904
$69,943
Time Adjusted Sale Ratio
1.7334
0.3564
0.439
0.4334
0.2602
Time Adjusted Sale Price per Acre
667.4793388
1120.787623
1609.82906
1456.848097
2536.924193
1456.8481
Site
Effective Frontage (F)
1,431.61
Actual Frontage
1431.61
Effective Depth (F)
Actual Depth
Effective Site Area (Acres)
80.52
35.55
Actual Site Area (Acres)
80.52
48.4
35.55
30.42
56.22
27.57
Effective Lot Size Unit of Measurement
A
Lot Size Unit of Measurement
A
Access
Summer Or Seasonal Access Only
Year Round Road Access
Year Round Road Access
Year Round Road Access
Year Round Road Access
Year Round Road Access
Abuts Variable(s)
Proximity Variable(s)
On Site Variable(s)
(8) 51% - 75% Swamp
(7) 26% - 50% Swamp , (2)
Pond On Property
(O) Gravel Road
Waterfront Variable(s)
Water Service Code
None But Potential To Connect To One Of The Above
Unspecified Service
Unspecified Service
None Available
Unspecified Service
None But Potential To Connect To One Of The Above
Sanitary
None
Unspecified Service
Unspecified Service
None
Unspecified Service
None
Variance
Regular
Irregular
Irregular
Regular
Irregular
Irregular
Hydro Code
No Hydro Available
Hydro Available
Hydro Available
Hydro Available
Hydro Available
No Hydro Available
Rate Per Acre Industrial Land
Excess Land
Residential Structure
Structure Code & Desc.
Structure Condition Code
Farm Structure(s)
Structure Description
(220) Silo / Open Top
Year Built
1930
Building Total Area (SF)
Quality of Construction
5
Height
26
Structure Description
(275) Miscellaneous Shed
Year Built
1930
Building Total Area (SF)
277
Quality of Construction
5
Height
10
Structure Description
(201) Type I Barn
Year Built
1900
Building Total Area (SF)
2235
Quality of Construction
4
Height
Farm Land
Farm Lands Class 1 Area
0
0
0
0
0
0
Farm Lands Class 2 Area
0
0
0
0
0
1
Farm Lands Class 3 Area
0
0
0
0
0
0
Farm Lands Class 4 Area
0
17.14
11
0
13.22
3
Farm Lands Class 5 Area
23
0
0
18
0
0
Farm Lands Class 6 Area
57.52
31.26
24.55
12.42
43
23.57
Appendix E – Market Analysis Grid Attachment 1