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Agricultural Valuations
A Practical Guide

R G Williams FRICS, FAAV

2008

A division of Reed Business Information

Estates Gazette
1 Procter Street, London WC1V 6EU
First published 1985
Second edition 1991
Third edition 1998
Fourth edition 2008

© R G Williams, 2008

ISBN 978-0-7282-0551-2

Apart from any fair dealing for the purposes of research or private study, or
criticism or review, as permitted under the UK Copyright Designs and Patents
Act 1988, this publication may not be reproduced, stored, or transmitted, in
any form or by any means, without the prior written permission of the
Publishers, or in the case of reprographic reproduction, only in accordance
with the terms of the licences issued by the Copyright Licensing Agency in the
UK, or in accordance with the terms of licences issued by the appropriate
Reproduction Rights Organisation outside the UK. Enquiries concerning
reproduction outside the terms stated here should be sent to the Publishers.
The Publishers and author make no representation, express or implied,
with regard to the accuracy of the information contained in this publication
and cannot accept any legal responsibility or liability for any errors or
omissions.
The material contained in this publication constitutes general guidelines
only and does not represent to be advice on any particular matter. No reader
or purchaser should act on the basis of material contained in this publication
without first taking professional advice appropriate to their particular
circumstances. The Publishers and author expressly disclaim any liability to
any person who acts in reliance on the contents of this publication. Readers of
this publication should be aware that only Acts of Parliament and Statutory
Instruments have the force of law and that only courts can authoritatively
interpret the law.
Copying in any form (including all hard copy and electronic formats) is
strictly forbidden without written permission from the Publishers, Estates
Gazette, a division of Reed Business Information.

Cover design by Rebecca Caro

Image courtesy of Rex Features
Typeset in Palatino 10/12 by Amy Boyle
Produced by Elsevier Architectural Press
Contents

Foreword. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
Preface to the fourth edition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii
Preface to the first edition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ix
Table of Statutes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xi
Table of Statutory Instruments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiii
Table of Cases. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xv

1 History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2 Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

3 Produce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

4 Growing Crops . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

5 Tenant’s Pastures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

6 Unexhausted Value of Feeding Stuffs, Manure and Lime . . . . 31

7 Sod Fertility Claims . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39

8 Tenant’s Improvements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

9 Tenant’s Fixtures. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49

10 Offgoing Crops (or Away Going Crop) . . . . . . . . . . . . . . . . . . . 53

11 Dilapidations. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

iii
Agricultural Valuations

12 Pipelines, Capital, Easement Payments and Claims. . . . . . . . . 79

13 Electricity Line Wayleaves and Claims. . . . . . . . . . . . . . . . . . . . 89

14 Notices to Remedy Breaches of Tenancy Agreement . . . . . . . . 93

15 Probate Valuations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 105

16 Stock Taking or Income Tax Valuation . . . . . . . . . . . . . . . . . . . 113

17 Valuation of Freehold Farms . . . . . . . . . . . . . . . . . . . . . . . . . . . 119

18 Inventories (Records). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133

19 Compulsory Purchase Claims . . . . . . . . . . . . . . . . . . . . . . . . . . 137

20 Farm Rents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 165

21 Valuation Clauses on Sales of Farms. . . . . . . . . . . . . . . . . . . . . 181

22 Records of Condition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 185

23 Livestock . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 191

24 Arbitration and Independent Expert Determination . . . . . . . 199

25 Milk Quotas. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 231

26 Soil Climate and Productive Capacity . . . . . . . . . . . . . . . . . . . 253

27 Managing Land Notified as a SSSI . . . . . . . . . . . . . . . . . . . . . . 269

28 Agricultural Tenancies Act 1995 . . . . . . . . . . . . . . . . . . . . . . . . 279

29 Valuations in Court Proceedings . . . . . . . . . . . . . . . . . . . . . . . . 293

30 Glossary of General Information . . . . . . . . . . . . . . . . . . . . . . . . 307

31 Advice to Young Practitioners . . . . . . . . . . . . . . . . . . . . . . . . . . 319

Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 327

iv
Foreword

Agriculture, like any other industry, continues to evolve and to change

with ever increasing demands from politicians, the consumer and the
environment together with the economic pressures that seem to be never-
ending. This is certainly true since Gwyn Williams produced the last
edition of the Agricultural Valuations 10 years ago. In particular the
industry has had to adapt to the changes imposed by the introduction of
the single farm payment system and every one has had to re-examine their
businesses in the light of the changes from production support to the new
system. This change was further complicated by the introduction of an
area based support system in England with a completely different system
in Wales and Scotland.
As a result of these changes, valuers businesses have also changed
with a considerable growth in advisory work, particularly in relation to
environmental schemes and rather less on traditional income streams. It is
also 10 years since the introduction of the Agricultural Tenancies Act. This
has altered the terms of occupation of large areas of the countryside.
Taxation issues have also been more prominent, considerable thought
has now to be given before much advice can be given to our clients on a
range of topics. In particular where we wish to retain agricultural relief
with recent case law favouring the Revenue.
On behalf of the Central Association of Agricultural Valuers, I am
delighted to recommend this book to all those involved in the profession,
from students, probationers and qualified members. I believe that this
new publication will again be essential reading to all who are involved in
the professions in the countryside. I would also congratulate Gwyn
Williams for his continuing excellent service to the profession.

P G Martyn FRICS FAAV

President CAAV 2007/2008, Beeston, Cheshire

v
This page intentionally left blank
Preface to the
fourth edition

Ten years have elapsed since the publication of the third edition. Much
has changed in the agricultural sector. With the passing of the
Arbitration Act 1996, the Planning and Compulsory Purchase Act
2004, the Regulatory Reform (Agricultural Tenancies) (England and
Wales) Act October 2006, the law relating to agricultural properties
and tenancies has dramatically changed.
Also, the decisions in the Antrobus and the McKenna cases affecting
inheritance tax has had a marked effect on tax liability in respect of
farms and farmland. It therefore became necessary to update this
publication.
I am indebted to the following for their help and assistance in
preparing and amending various chapters — David Carter, Paul
Wright, Tony Carver, Glenys Tucker, Geoff Coster, Michael Hardman,
Tim Swallow, Alan Lane, Lee Ward, Stephen McLaughlin and Greg
Christopher. Also two very competent and patient secretaries — Miss
C Morgan and Miss C Pearson for typing and re-typing.
In particular I would like to thank the President of the Central
Association of Agricultural Valuers, Graham Martyn, for writing the
foreword and the President and Council of the CAAV for permission
to make use of some of their specialised information on costings etc
and, in particular, Jeremy Moody CAAV Adviser for checking the
legalities quoted and for helpful advice.
R G Williams
Ross-on-Wye
May 2008

vii
This page intentionally left blank
Preface to the
first edition

This book started its life as a few articles dealing with specific types of
valuation, written for the benefit of a number of young agricultural
valuers, to assist in their professional examinations. I have been
encouraged by several practitioners to develop these articles into book
form and this publication is the result. Many young agricultural
valuers have, over the last few years, had considerable difficulty in
obtaining proper experience in agricultural valuations. The problems
have increased as firms have become specialised, the work-load of
principals has changed and increased, resulting in little time being
available to instruct young valuers. I was further encouraged to
publish this book as there is no similar, up-to-date publication,
currently available.
Some valuers may consider that some of the figures given in the
example claims are high and in some cases items may even appear to
be duplicated. Nevertheless, it is the duty of any claimant’s valuer to
prepare a proper and full claim as he may otherwise be negligent, if he
does not do so. Valuation is not an exact science and virtually every
claim made by a practitioner is subsequently negotiated.
This book is essentially a practical guide drawn from more years
experience in the profession than I care to remember. The views
expressed and methods of valuation are, as I use, and interpret
matters. Whilst every effort has been made to ensure the accuracy of
the information given and opinions expressed, I cannot, however,
accept any responsibility for any inaccuracy of these interpretations
and valuation methods. I hope this book will prove to be of value as a
practice guide to young and older valuers alike.
I would like to take this opportunity of expressing my appreciation
to the President and Council of the Central Association of Agricultural

ix
Agricultural Valuations

Valuers for allowing me to use some of their published costings and

also their encouragement in writing this book.
My special thanks go to Mr Alan N Lane, FRICS, CAAV of
Knutsford who has corrected the manuscript, written the article on
pigs and also given me many valuable suggestions. Also to the
following who have given valuable advice:
Mr Robert Thomas, MA, FRICS, CAAV Cowbridge; Mr Alan Brown,
FRICS, CAAV Newport; Mr Malcolm Williams, CDA Ross-on-Wye
and a leading compensation valuer.
I further wish to thank the following members of my own firm for
checking the calculations, advice and making suggestions:
Mr Nigel Morris, ARICS, NDA, CAAV; Mr Michael Taylor, BSc,
ARICS and my son Mr Richard Williams, BSc, ARICS, ASVA, CAAV.
Finally thanks go to four very patient secretaries who have typed
and re-typed this work.

October 1984 R G Williams

Coles, Knapp & Kennedy
Ross-on-Wye

x
Table of Statutes

Agricultural Holdings Act 1875 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Agricultural Holdings Act 1923 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2
Agricultural Holdings Act 1948 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3
Agricultural Holdings Act 1986 . . . . . . . . . . . . . . . . . . . . . . . . . . .61, 165
Agricultural Tenancies Act 1995 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .279
Agriculture Act 1947 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .73
Agriculture (Miscellaneous Provisions) Act 1968 . . . . . . . . . . . . . . . .138
Agriculture (Miscellaneous Provisions) Act 1976 . . . . . . . . . . . . . . . .316
Arbitration Act 1996 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .199

Capital Transfer Tax Act 1984 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .276

Compulsory Purchase Act 1965 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138
Countryside & Rights of Way Act 2000 . . . . . . . . . . . . . . . . . . . . . . . .269
Crow Act 2000 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .270, 271

Gas Act 1986 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .79

Land Clauses Consolidation Act 1845 . . . . . . . . . . . . . . . . . . . . . . .3, 277

Land Compensation Act 1961 . . . . . . . . . . . . . . . . . . . . . . . . . . . .137, 277
Land Compensation Act 1973 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138

Natural Environment & Rural Communities Act 2006 . . . . . . . . . . .272

Planning and Compensation Act 1991 . . . . . . . . . . . . . . . . . . . . . . . . .138

Planning and Compulsory Purchase Act 2004 . . . . . . . . . . . . . . . . . .139
Poor Relief Act 1601 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1

xi
Agricultural Valuations

Regulatory Reform Order (TRIG) SI 2006 No 2805 . . . . . . . . . . . . . .283

Water Industry Act 1991 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .79

Wildlife and Countryside Act 1981 . . . . . . . . . . . . . . . . . . . . . . . . . . . .269

xii
Table of Statutory
Instruments
Agricultural Holdings (Arbitration on Notices) Order 1987
(SI 1987 No 710) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .93, 101
Agricultural Holdings (Forms of Notice to Pay Rent or to
Remedy) Regulations 1987 (SI 1987 No 711) . . . . . . . . . . . . . . . . .93
Agriculture (Calculation of Value for Compensation) Regulations
1978 (SI 1978 No 809) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .31, 35
Agriculture (Calculation of Value for Compensation)
(Amendment) Regulations 1981 (SI 1981 No 822) . . . . . . . . . . . .31
Agriculture (Calculation of Value for Compensation)
(Amendment) Regulations 1983 (SI 1983 No 1475) . . . . . . . .31, 35
Agriculture (Maintenance, Repair and Insurance of Fixed
Equipment) Regulations 1973 (SI 1973 No 1473) . . . . . . . . . . . . .75

Conservation (Natural Habitats, etc) Regulations 1994

(SI 1994 No 2716) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .272, 276

xiii
This page intentionally left blank
Table of Cases

Anderson v Moray District Council 1978 SLT 37 . . . . . . . . . . . . . . . . 145

Antrobus Case see Lloyds TSB Private Banking plc v Twiddy

Barton v Lincolnshire Trust for Nature Conservation (ALT)

(1997) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .46

Calderbank v Calderderbank [1975] 3 All ER 333 . . . . . . . . . . .206, 226

Childers (JW) Trustees v Anker (CA) [1996] 1 EGLR 1 . . . . . . . . . . .225
Clouds Estate Trustees v Southern Electricity Board [1983]
2 EGLR 186 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .91
Cuthbert v Secretary of State for the Environment [1979]
2 EGLR 183 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .140, 142

Evans v Jones [1955] 2 QB 58 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .71

George v South Western Electricity Board [1982] 2 EGLR 214 . . . . . .91

Lloyds TSB Private Banking plc v Twiddy [2006] 1 EGLR 157 . . . .150

McKenna Case (CJF Arnander, DTM Lloyd and MM Villiers

ex/ors of David McKenna d/d and Lady Ceciliar McKenna
d/d v HMRC SPC 00565 23.10.2005) . . . . . . . . . . . . . . . . . . . . . .106

Naylor v Southern Electricity Board [1996] 1 EGLR 195 . . . . . . . . . . .91

Pearce v Ove Arup Partnership Ltd . . . . . . . . . . . . . . . . . . . . . . . . . . .298

Phillips v Symes [2004] EWHC 2330 . . . . . . . . . . . . . . . . . . . . . . . . . .295

xv
Agricultural Valuations

Puncknowle Farms Ltd v Kane [1985] 2 EGLR 8 . . . . . . . . . . . .139, 236

Robertson Aikerman v George (1953) 103 LJ 496 . . . . . . . . . . . . . . . . .72

Stanton v Callaghan [2000] 1 QB 75 . . . . . . . . . . . . . . . . . . . . . . . . . . .298

St Johns College Oxford v Thames Water Authority (ALT)
[1990] EGCS 36 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .79
Surrey County Council v Main [1992] 1 EGLR 26 . . . . . . . . . . . . . . .240

Tummon v Barclays Bank Trust Co Ltd [1979] 1 EGLR14 . . . . . . . . .173

Wakerley v St Edmundsbury Borough Council (1977) 241 EG 921

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .145, 147

xvi
History

1.1
1
Agricultural valuations, as commonly known, can be said to
have started as the assessment of tenant right payments, when a tenant
quitted an agricultural holding. Such a valuation was known as a
tenant right valuation. Tenant right compensation started around 1775
when there was considerable agricultural activity and progress in the
country.

1.2 This compensation was paid for on a basis of custom, which

developed over the whole country and often varied from county to
county and in some cases from estate to estate. The work of assessing
the claim was done by farmer valuers, who were well known and
respected farmers in the areas in which they lived. These men
eventually formed county and area tenant right valuers’ associations.
Most of these were formed after the passing of the Agricultural
Holdings Act 1875, when it became necessary to agree to a uniform
basis, in their district, of assessing compensation for the various matters
of claim.

1.3 The oldest known valuers’ association was founded in the

county of Suffolk in 1847. In 1910 a number of these valuers’
associations joined together to form the Central Association of
Agricultural Valuers, which, today, is the foremost agricultural and
tenant right valuers’ professional organisation in the country.

1
Agricultural Valuations

1.4 The items to be paid for as tenant right, under custom, were
variously: hay, straw, dung, growing crops, acts of husbandry (tillage
operations), compensation for feeding stuffs consumed by animals,
fallows, offgoing or awaygoing crops, pre-entry (ie entry on to the
holding in advance of the date of the tenancy, eg to plant crops),
boosey pasture and holdover (ie right to keep a small field for a cow
or horses from quitting day of say Candlemas (2 February) until
Whitsunday (15 May)).

1.5 With the passing of the Agricultural Holdings Act 1923 and
particularly the Agricultural Holdings Act 1948, with their intricacies,
the farmer valuers began to die away and the work was undertaken by
professional agricultural valuers. However, farmer valuers did not
completely disappear until about 45 years ago.

1.6 Prior to this, assessments of the value of land were made for the
relief of the poor following the passing of the Poor Relief Act 1601.

1.7 The work of the professionals was further increased during the
railway construction era of the 19th century when considerable areas of
land were compulsorily acquired and compensation had to be assessed
under the provisions of the Land Clauses Consolidation Act 1845.

1.8 The introduction of death duties by Mr David Lloyd George in

his budget of 1910 further increased the work of an agricultural valuer
as the landed gentry were assessed also on the value of their estates.

1.9 Nevertheless, most of the work of an agricultural valuer, as we

know it today, has been extended considerably since the end of the
Second World War and is very specialist in nature. Nowadays, it
covers not only tenant right valuations, but also rental valuations,
agricultural property valuations for many purposes including
compulsory acquisition, purchase, sale, inheritance tax and capital
gains tax. It also covers compensation claims for easements (gas, water
and oil pipelines, electricity lines), compensation for opencast and
other mineral extraction, milk quotas, SSSIs, etc.

2
Definitions

2.1 Termination of tenancies claims

2
Chapters 1–11 of this book deal in termination of tenancy claims and it
is expected that the practitioner has a working knowledge of the
Agricultural Holdings Act 1986. Unless otherwise stated, the valuation
examples given in Chapters 3–11 are all on the basis prescribed by the
1986 Act and, in particular, the Agriculture (Calculation of Value for
Compensation) Regulations 1978 (SI 1978 No 809), the Agriculture
(Calculation of Value for Compensation) (Amendment) Regulations
1981 (SI 1981 No 822) and the latest amending Agriculture (Calculation
for Compensation (Amendment) Regulations 1983 (SI 1983 No 1475).

2.2 Definitions
In computing the relevant valuations, it is well to be reminded of the
following factors which are important.

2.2.1 Pre 1 March 1948 tenancies

Some of these still exist even today, 60 years later. Compensation for
tenant right, ie growing crops, harvested crops, root crops, seeds sown,
pasture, sod fertility, acclimatisation of hill sheep, etc, will not be paid
under the provisions of Part II of schedule 8 of the 1986 Act, unless
before the termination of the tenancy, the tenant serves a written notice
under para 6 of schedule 12 electing that those provisions shall apply

3
Agricultural Valuations

to him. If no such notice is served, compensation for tenant right will

be payable under the custom of the district and the provisions of the
tenancy agreement.

2.2.2 Consuming value

This is defined in SI 1978 No 809, Part II 8(3) as being the market value
for consumption on the holding by agricultural livestock of hay,
fodder, crops, straw, roots and other crops or produce of good quality
less the manurial value, on a no crop off basis as prescribed by Tables
5(a) and (b) of SI 1983 No 1475.
Local valuers’ associations normally fix consuming values for
various produce and crops twice a year. These figures reflect the
deduction for the manurial values of the crops. The values fixed
normally refer to the best quality crops, situated in a good position, etc.

2.2.3 Market value

There is no official definition of market value but this is considered to
be what the open market would give for any commodity, without
restriction on where it was consumed, eg the market value of a bay of
hay is what is considered could be obtained for the same if sold by
open auction. Likewise, the market value of an area of swedes is what
the open market would give for the same, either for folding off or on
harvesting and removal from the holding.

2.2.4 Spring tenancy (SI 1978 No 809, Part II 8/2)

This means a yearly tenancy which commenced between 1 January
and 30 June, inclusive.

2.2.5 Autumn tenancy (SI 1978 No 809, Part II 8/2)

This means a yearly tenancy which commenced between 1 September
and 31 December inclusive.

4
 Definitions

2.2.6 Enhancement value (SI 1978 No 809, Part II

8/1(c))
This applies to autumn sown crops where the land is held under a
spring tenancy or grass and clover seeds which are sown on the land
held under a spring or autumn tenancy where no crop has been taken
at the termination of the tenancy.
The enhancement value is an additional amount payable which
represents the enhancement of the value of that crop to an incoming
tenant, but this shall not exceed the rental value at the termination of
the tenancy.

2.3 Tenant right valuations

It is stressed that in all the chapters dealing with tenant right there is
no contract between the outgoing tenant and incoming tenant.
The only contract the outgoing tenant has is with the landlord and
a tenant right valuation is in theory carried out between the outgoing
tenant and the landlord. Normally, however, one valuer acts for the
outgoing tenant and another valuer acts for both the landlord and the
incoming tenant (if there is one).

2.4 Claims
Under section 83(2) of the Agricultural Holdings Act 1986 landlords’
and tenants’ claims must be notified before the expiration of two
months, ie after the termination of the tenancy. Under section 83(4) of
the 1986 Act eight months are allowed for settlement, failing which,
the matter shall be determined by arbitration under the Arbitration
Act 1996. Note, however, that if the landlord is claiming for general
deterioration of the holding, he must give the tenant notice of his
intent to claim under section 72 of the Act no later than one month
before the termination the tenancy.

5
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Produce

3.1 Produce
3
Produce comprises harvested hay, straw, silage and roots.

3.2 Hay
Distinguish between seeds and meadow hay. Good meadow hay is
fine hay from old pastures and is very suitable for calves and sheep.
Seeds hay is from ryegrass, timothy and clover mixtures. Best hay
should be leafy, bright, green, smell sweet, be cut young and not be
fibrous. Hay suitable for horses has all of these qualities but is seeds
hay and free from dust. Avoid fousty, dusty, fibrous, rain washed and
overheated hay. Baling too soon and too tightly can spoil hay.

3.2.1 Valuation
3.2.1.1 Conventional bales
Weigh say six bales in a bay, preferably from different layers and get
average weight in kgs. Count number of bales, multiply weight by
number of bales and divide by 1000 = number of tonnes, eg 920 bales
average 20.4 kg in bay:

920 × 20.4/1,000 = 18.768 tonnes

7
Agricultural Valuations

Volume method
Sometimes it is not possible to count bales. An alternative method is to
obtain the cubic content of the stack in m3 and divide by an
appropriate density figure:

Very compact: 6–7 m3 per tonne

Medium: 8–9 m3 per tonne
Unsettled: 10–11 m3 per tonne

Practice checks
Small bales of hay often approximate at 50 bales per tonne. Medium
and heavy bales often weigh from 18 to 22 kg per bale. Discount any
weathered bales on the exposed side of barns and also possibly half or
sometimes the whole of the bottom layer as this might be damp. Look
out for voids in the stack. The bottom layer has usually more bales
than the other layers since they are laid on edge. As a rule a bay 24ft
(7.3m) × 15ft (4.5m) × 18ft (5.4m) will contain approximately 20 tonnes.

3.2.1.2 Big bales

Nowadays big balers are used on most farms in preference to
conventional balers. Two types are generally used.

(a) Round balers

These are usually of two types each producing a cylindrical bale of
about 1.5m wide × up to 1.8m diameter or 1.2m wide × up to 1.5m wide.
Note the density of bale made can be controlled and sometimes as a
result bales may be very dense and thus heavier. Usually one round
bale contains between eight and nine small bales, but this can vary.

(b) Rectangular balers

Two types are in use, namely a low density baler producing a bale
about 1.5 × 1.5 × 2.4m in size and a high density baler producing a bale
of about 1.2 × 1.3 × 2.4m. Often the weight of hay in big rectangular
bales made by a high density baler is anything between 600 and 700 kg.

8
 Produce

3.2.1.3 Valuing big bales presents a major problem to an agricultural

valuer since sample bales cannot easily be weighed. However, it is
essential that say three or four bales are weighed and an average
weight obtained. Often this means that they have to be transported to
the nearest available weighing facility.
When the weight has been determined, the value can be assessed.
This may be on a consuming basis (the local agricultural valuers’
association may fix the values) which may need adjusting having
regard to:

(a) the quality of the hay

(b) the quantity does not exceed the quantity reasonably required for
the system of farming practised
(c) how convenient it is for use
(d) how well it is stacked and protected.

3.2.1.4 Points to note

(a) Big bales are not as easy to handle as small bales. They must be
handled mechanically.
(b) Not every farmer has the desire to use big bales and some prefer
small ones.
(c) They may have been left out in the fields longer than small bales.
The quality of the hay suffers in wet weather conditions especially
rectangular bales.
(d) If the bales are out in the open but covered with polythene
sheeting, unless placed on concrete they are likely to be damp and
there could be considerable wastage.

3.3 Straw
Wheat straw is usually used for bedding only. Spring barley straw is
best for feeding. Winter barley straw is of secondary feeding value as
it is brittle. Oat straw is also used for feeding but winter oat straw also
tends to be brittle. The most valuable straw is, therefore, spring barley
straw.
Feeding straw should be bright, not dusty, damp or weathered
and the bales light. Wheat and oat straw bales are usually heavier than
barley bales. Frequently there are about 60–80 small bales of barley
straw to the tonne.

9
Agricultural Valuations

3.3.1 Valuation
3.3.1.1 Conventional bales
The method is as for hay, subject to the following amendments on the
density system (where bales cannot be counted).
Heavy: 10–11 m3 per tonne
Medium: 12–13 m3 per tonne
Light: 14–16 m3 per tonne

3.3.1.2 Big bales

Many of the comments made about big hay bales apply to straw and
sample bales must be weighed. Often one round bale contains between
eight and nine small bales. Often big straw bales are left out in the open
but do not suffer, as a rule, if they are wrapped. However, there is
considerable wastage and deterioration in quality after a few weeks’
exposure to rain and the weather generally where bales are not
wrapped. Big bales stacked in a heap tend to become very wet resulting
in considerable wastage.

3.3.1.3 Valuation is on the same basis as for hay, using the relevant
figures prescribed by the local agricultural valuers’ association.

3.4 Silage
3.4.1 Clamp silage
In the absence of market value evidence this should be valued on the
basis recommended by the CAAV [Numbered Publication 183] and
DEFRA. It should always be analysed and such analysis should be
used in assessing both the density and the value of silage. Research by
ADAS has shown that there is direct relationship between dry matter
percentage and dry matter density of clamp silage. Analysis will give
digestibility (‘D’ values). Values below 50 are poor and above 72 good.

• Soil contamination — this is indicated by the ash content which

should be under 10%.
• Fermentable ME (metabolised energy) — values above 10
megajoules/kilogram corrected dry matter are expected and
those below 8 are poor.

10
 Produce

• pH levels between 3.8 and 4.3 are normal to good while values
below 3.8 are poor.
• Crude protein (CP) — values in the range 10–16%.
• Ammonia H — well fermented value less than 10% of total H.

The bulk density varies considerably with grass clamp silages having
densities of between 475 and 1100kg/m3. In a CAVV survey in 2006,
30% of samples had densities between 700 and 900kg/m3. An average
density is above 800kg/m3.
Maize silage density is less than grass silage with an average 34%
DM of 680kg/m3.
Grass silage has a light green, greenish yellow or greenish brown
colour and should smell pleasant, fruity or faintly acid and the texture
should be firm. Dark brown or black silage is overheated. Olive green
or dark green silage is underheated and has a strong rancid, musty
smell. Sometimes secondary fermentation occurs and the silage
becomes a brown colour and smells fishy or musty and is rather slimy
in texture.
Care should be taken in measuring silage. If the bunker walls are
lined with plastic sheeting at the side there is usually a good deal less
waste than when unlined. Proper allowance should be made for
wastage at the sides, the wedge and also the top where sometimes as
much as 150mm (6in) is waste.
Great care should be taken in analysing silage as often three or
four cuts are taken and there can be considerable variation in the
analysis of the various cuts. Often four samples are taken from four
different points on the clamp and all are put in the same bag and
analysed as one.
Precision chopped silage in clamps is usually easier to self-feed
than single or double chop. Bagged silage is always cut by a mower
(not precision chopped) and usually baled direct and then bagged or
wrapped.

3.4.2 Big bale silage

This should have sample analysis of at least 5% of the bales. In many
cases valuation of bagged and wrapped silage will be found to work
within the formula given below, but results provided by high DM
percentages should be treated with caution.
If the plastic bags are punctured or badly sealed the silage is of
little value and often the whole bag is ruined. The outgoer is

11
Agricultural Valuations

responsible for weighing a sufficient number of bales to establish the

weight. Market price is the best measure of value as generally there is
some sales evidence available.

3.4.3 Maize silage

Maize for silage is a popular crop, grown almost all through the land.
It is high in starch, has high digestibility (D value to be 60 to 70) and is
low in protein. It can yield from 15 to 25 tonnes per acre. However, it
is not a cheap crop to grow and occupies the land for a long period —
late April to October.

3.4.4 Valuation
The CAAV recommend that where market value evidence is available
this should be taken into account having regard to the valuation basis
given in SI 1978 No 708 as amended by SI 1980 No 750, SI 1981 No 822
and SI 1983 No 1475. This is the market value for consumption by
agricultural livestock on the holding — produce of good quality less
the manurial value thereof calculated on the basis of no crop off,
provided that if the value so calculated exceeds the value to an
incoming tenant in any case where:

(a) the crops or produce are of inferior quality

(b) the quantity of any kind of crop or produce exceeds the quantity
reasonably required for the system of farming practised on the
holding or
(c) the crops or produce are left in convenient or proper places on the
farm or

the value so calculated shall be reduced so as not to exceed such actual

value.
The CAAV recommend that where market value evidence is not
available, silage may be valued by reference to the value of the
tradeable feeds on the basis of the benefits they offer stock. This
approach is based on two baskets of common feeds which are
regularly used and traded. One basket contains mainly energy food
(feeding barley straw, good hay, barley, wheat, beet pulp and maize
gluten). The other basket contains mainly protein foods (Brazilian
soya, rape meal, beans, peas and distiller grains).

12
 Produce

The method of valuation is to calculate the average energy and

protein content of the two baskets. The value of the commodities is
published in the weekly reports, as published in Farmers’ Weekly. Then
apply the following formulae:

ME (Average cost of energy feeds × 39) – (Average cost of protein feeds × 14)
213

Note: The figures 39, 14 and 213 will remain constant.

CP (Average cost of protein feeds × 12.9) – (Average cost of energy feeds × 15.6)
213

Note: The figures 12.9, 15.6 and 213 will remain constant.
These unit values can then be multiplied by the energy and
protein contents of the silage (bearing in mind its dry matter) to give a
basic value for the silage as follows:

Unit Price ME × ME% × DM%/100 + Unit Price CP × CP% × DM%/100

The resulting value may be adjusted by any of the following factors to

reflect a proper value of the silage in question and taking into account
transaction evidence of silage value where:

(a) Ammonia levels

Adjustment

Ammonia % Adjustment Ammonia % Adjustment

0–10% Nil 24% –23%
11% –1% 25% –25%
12% –2% 26% –28%
13% –3% 27% –31%
14% –4% 28% –34%
15% –5% 29% –37%
16% –7% 30% –40%
17% –9% 31% –43%
18% –11% 32% –16%
19% –13% 33% –49%
20% –15% 34% –52%
21% –17% 35% –55%
22% –19% 36% –58%
23% –21% 37% –60%

13
Agricultural Valuations

(b) Starch content

Formula is:
silage value × 100
Silage value corrected for starch =
(120 – starch %)

(c) Other relevant factors

The value of the silage should be adjusted having regard to factors
such as exceptional and inferior quality, position of clamp on the farm,
time of year and whether clamp is open or under cover and whether
properly covered.

(d) Valuations under 1986 Act

Deduct for manurial value (Table 5(a) of SI 1978 No 809).

Example valuation
Stage 1
Obtain current prices per tonne for the feeds in the two baskets and calculate the
average for each basket. The values used in this example are purely illustrative.
They will of course change over time and so will need to be checked for
valuations at new dates.

Energy Feeds Protein Feeds

Barley Straw £35.00 Brazilian Soya £172.00
Hay £50.00 Rape Meal £125.00
Barley Grain £110.00 Beans £130.00
Wheat Grain £120.00 Peas £130.00
Maize Gluten £135.00 Distillers Grains £120.00
Beet Pulp £100.00
Average £91.66 Average £135.40

Stage 2
Assess the cost of a unit of ME in the basket of energy feeds using the ME
equation.

(£91.66 {= average cost of energy basket} × 39) – (£135.40 {= average cost of protein basket} × 14)

213

14
 Produce

3574.74 – 1895.60 1679.14

= = = £7.88 per unit of ME
213 213

NB The figures of 39, 14 and 213 are constants.

Stage 3
Assess the cost of a unit of CP in a basket of protein feeds by using the CP
equation.

(£135.40 {= average cost of protein basket} × 12.9) – (£91.66 {= average cost of energy basket} × 15.6)

213

1746.66 – 1429.89 316.77

= = = £1.48 per unit of CP
213 213

NB The figures of 12.9, 15.6 and 213 are constants.

Stage 4
Calculate the feed value of the silage by using the unit values in the equation for
energy and protein content.
Assuming the silage has been analysed to show

• ME of 10.6MJ/kg
• DM of 21.0%
• CP of 13.0%

the figures are

7.88 × 10.6 ME × 21% DM 1.48 × 13% CP × 21% DM

+
100 100

= £17.54 + £4.04 = £21.58 per tonne

Stage 5
Adjust for high ammonia levels using the table at paragraph (a) .
Thus, if the silage analysis showed an ammonia content of 12%, then a 2%
deduction, 43p should be made which in this case would reduce the value to
£21.15 per tonne.

15
Agricultural Valuations

Stage 6
Where maize (or later wholecrop) silage is involved, adjust the value for starch
content according to the formula:

silage value × 100

Silage value corrected for starch =
(120 – starch %)

Stage 7
Value the clamp of silage by making further allowances for any relevant factors.

Stage 8
If required to value on consuming basis (as for the end of a 1986 Act tenancy),
deduct for manurial value as follows:

(DM% of silage)
UMV Hay ×
85

Stage 9
Again if required by the 1986 Act, reduce the value effecting any inconvenience
in location inferior quality or excess quantity of the silage.

3.4.5 Tower silage or haylage

In practice a tower silo of 20ft (6m) diameter has a capacity of 2 tonnes
dry matter per foot of depth of silage, a 24ft (7.3m) diameter silo has a
capacity of 2.75 tonnes per foot and a 30ft (9.12m) diameter silo about
4.4 tonnes dry matter.
It is strongly recommended that a valuer should study the silo
capacity given by the manufacturer.
Advisers recommend that the dry matter capacity (note this is
different from the actual capacity — dry matter content of fresh silage
is taken at 40%) can be calculated on the following formula:
DM capacity (tonnes) = 6.08 × d × 2h (17.4 + h)/1,000

d = diameter in metres
h = settled silage height in metres

Often it works out at 1.55 to 1.77 m3 per tonne (560 to 65 kg per m3) at
45 to 50% dry matter (240 kg dry matter per m3).

16
 Produce

In computing the valuation, it is necessary to have the haylage

analysed. Difficulty can arise in getting samples from a tower silo
except at the bottom and before a valuation is settled, delay may arise
in having to wait before further samples can be taken for analysis.
Having obtained suitable analysis, it is suggested that the valuation
should be done using the same formula as for clamp silage. Normally
haylage has a much higher dry matter content than clamp silage and
should have a much higher feeding value and thus, a higher value per
tonne than silage.

3.5 Harvested roots

The volume is calculated and the following are the amounts in m3 and
cu ft per tonne.

m3 per tonne cu ft per tonne

Mangolds 1.78 64
Swedes 1.78 64
Potatoes 1.55 55
Fodder Beet 1.78 64

Local valuers’ associations, at their price fixing meetings, sometimes

fix prices per tonne for these roots (in areas where they are grown) and
this is done on the basis of the market value less the manurial value in
a no crop off basis in accordance with the SI 1978/809 (as amended).

17
This page intentionally left blank
Growing Crops

4.1
4
These are valued on the basis of cost of seeds, fertilisers,
cultivations, fallows and acts of husbandry plus, in the case of
autumn sown crops on a holding held on a spring tenancy, or grass
and clover seeds sown in a spring or autumn tenancy where no crop
has been taken, an additional amount representing the enhancement
value to the incoming tenant of the growing crop not exceeding the
annual rental value of the area carrying the crop. Often, the rent paid
for the appropriate period of the growth of the crop is added as the
enhancement value.

4.2 It is necessary to know the cultivations that are normally carried

out. These are usually much less costly on light land than on heavy
clay land. Note the action of frost on heavy land ploughed over winter
improves the tilth considerably. Also note the increasing use of
minimal cultivation or no-ploughing techniques (see below). Full
details of all cultivations carried out should be obtained from the
farmer. A specimen cultivation procedure on light land for, say, a
winter barley crop in Herefordshire may be:

Winter: 1 tramline lifting (subsoiling)

1 plough and press
1 fertiliser spreading
1 combination drilling (cultivate and drill)
1 pre-emergent spraying for weeds (herbicide)

19
Agricultural Valuations

Spring: 1–3 top dressings

1 spray for mildew
1 spray for weeds (herbicide) may be done in one
operation (if not done in the autumn)
1 rolling (possible).

Alternatively, for a crop of winter wheat on heavy land:

Winter: 1 plough
1 roll
2 disc harrows
1 combination drilling (cultivate and drill)
1 pre-emergent spraying for weeds (herbicide)

Spring: 1 roll
1–3 top dressings
2–3 sprayings.

4.3 No ploughing or minimal cultivations

Some farmers, particularly on heavy soils, do not plough, and have
found in practice that in using minimal cultivations the top layer of
soil has an improved texture and workability and resultant yields are
improved. An example of the technique used by an arable farmer on
heavy clay in Worcestershire (all winter corn) is:

• 1 spray (if the land is foul) to kill weeds and, if pasture, the grass)
• 1 subsoiling (every three years — but tramline lifting each year)
• 2 or possibly 3 heavy disc harrows
• 1 combination drilling (cultivate and drill)
• 1 harrow
• 2–3 sprayings.

4.4 Valuation
4.4.1 Winter wheat
The valuation is calculated in accordance with the costings issued by
the CAAV. An example of a winter wheat crop is as follows:

20
 Growing Crops

£ per acre £ per ha

Cultivations etc
1 subsoil (tramline) 19.50 48.20
1 plough 16.55 40.90
Fertiliser spreading 3.15 7.80
1 combination drilling 17.60 43.50
1 spray 2.50 6.20

Seeds (costing £300 per tonne)

185 kg 55.60
75 kg 22.50

Fertilisers (0:24:24 @ £180 per tonne)

308 kg 55.44
125 kg 22.50

Spray, pre-emergent herbicide 12.00 29.62

Enhancement value 25.00 61.77

141.30 349.00

4.4.2 Roots (in the ground)

Growing root and green crops (eg kale, stubble turnips) of a kind
normally grown on a holding held under an autumn tenancy are
valued on the basis of the average market value on the holding of good
quality crops less their manurial values as provided by SI tables. In
practice, the prices are fixed by the local agricultural valuers’
association in the autumn. Example valuations are (as at autumn 2007):

Marrow stem kale £150 per acre £370 per ha

Kale (other) £115 per acre £284 per ha
Stubble turnips £70 per acre £173 per ha

The yield of swedes, mangolds and turnips in the ground is estimated,

(this can be checked by cutting and weighing specimen areas) and all
are valued in the autumn of 2007 @ £10.15 per tonne.
The above values are for best quality crops and are net of the
deduction for manurial values.

21
Agricultural Valuations

4.5 Growing crops — market value basis

4.5.1 Occasionally, crops are required to be paid for on crop value or
market value basis, ie what that crop will realise if sold or taken over,
as a growing crop on the relevant date. Note, this is most likely to arise
under the contracts of sale of farms or form part of agreed surrender
terms.
In such valuations it is usual to assess the likely yield, price this
out at market value and then deduct the cost of harvesting and also a
percentage of risk (usually, dependent on stage of maturity of the crop,
10%–15%) in case it may never be harvested because of weather
conditions or losses on lodging (crop being laid). Examples are set out
at 4.5.2, 4.5.3 and 4.5.4.

4.5.2 Growing crop of barley

per acre per ha
Grain yield 3 tonnes @ £130 390 963
Straw yield 1 tonne @ £35 35 86
£425 £1,049

less: harvesting, carting and drying 40 98

risk: 10% of gross say 42 104
Crop value £343 £847

4.5.3 Growing crop of swedes

per acre per ha
Estimated net yield 15 tonnes @ £10 150 371
less: harvesting — nil (to be folded off) – –
risk: nil (if healthy — but if suffering
from disease say 25–50% + can be
deducted – –

Crop value £150 £371

Here it is observed that although these values are prescribed by local

valuers’ associations, it may prove in practice very difficult in some
seasons to get these figures on the open market. Also, where folded off,
about a quarter of every root is left in the ground as it cannot be eaten.
Market value evidence, if available, should be taken into account.

22
 Growing Crops

4.5.4 Growing crop of marrow stem kale

Note that this crop is very susceptible to frost damage, and it is most
unwise to agree to pay anything much for such crop after Christmas as
often frosts render the crop valueless. Marrow stem kale has now lost
popularity and hybrid kales, which are generally frost resistant and
weather durable crops, are of far greater value.

per acre per ha

Value (folded off) £120 £297

23
This page intentionally left blank
Tenant’s Pastures

5
The basis of valuation for tenant’s pasture is either of two kinds.

5.1 Cost basis

This basis is to be used where no crop has been removed by mowing
or grazing and when sown on land held under a spring or autumn
tenancy. The value is the reasonable cost of seeds sown, cultivations,
fallows and acts of husbandry performed, also taking into account any
expenditure incurred solely for the benefit of the pasture before the
removal of any crop in or with which this pasture was sown. Also
enhancement value shall be added.
It is very costly to establish leys, as shown in this example.

per acre per ha

Seeds (4/5 year ley) say 35.00 86.00
Cultivations namely:
1 plough and press 19.65 48.55
1 drill 7.10 17.60
1 fertiliser spinner 3.15 7.80
3 rolls (gang) 9.50 23.45
39.40 97.40
£74.40 £183.40

Note: Further harrowing or rolling may be necessary

25
Agricultural Valuations

Fertilisers 100 kg 20:10:10 16.00 39.53

247 kg 20:10:10

Enhancement value say 30.00 74.13

Total cost £120.40 £297.06

Short term leys (ie of one to three years) mainly of ryegrass and
possibly other grasses, cost almost as much to establish, the only
exception being that the seeds sown, cost approximately £10 per acre
(£25 per ha) less.
If the seeds are undersown (ie drilled in the spring in, say, a
growing spring barley crop), the labour costs will be much less.

per acre per ha

Seeds say £20.00 £49.40
Broadcasting seeds (spinner) £3.15 £7.78
Rolling £9.50 £23.45
£32.65 £80.63

However, the practice of undersowing corn with young seeds is now

less popular, many farmers preferring to sow them direct, in the
autumn, after cereals.

5.2 Face value basis

This basis is applicable where one or more crop has been taken by
mowing or grazing. In assessing the value of any particular pasture,
the following shall be taken into account.

(a) Present condition. Is it a good quality ley, well established, of a

good seeds mixture, clean and free from weeds, especially grass
weeds such as couch?
(b) Has it been properly managed since sowing? Leys can be ruined
by undergrazing.
(c) Is there water available for stock?
(d) Is the fencing good and stockproof? This is most important
(e) Is it convenient for access and also in relation to the remainder of
the farm?
(f) Is it near the end of its useful life and how much longer will it last
before it becomes unproductive?

26
 Tenant’s Pastures

(g) Is the ley dominated by certain grasses and clovers? Cocksfoot is

generally a coarse (though productive and drought resistant)
grass and if not properly grazed, will dominate a sward. Clover
adds considerably to the fertility of the land by nitrogen fixation.
However, where there is an excess in a sward, it causes blowing of
animals (bloat) which occasionally results in death.

If leys are properly managed, they can improve in quality after they
have been established a few years, provided, of course, the seeds
mixture is satisfactory and has become well established. Generally
speaking, leys do, however, deteriorate considerably towards the end
of their life.
Valuing leys accurately at face value is a difficult matter. In the
past, valuers have tended to put rather low values on good leys which
have considerable unexpired life and productivity. The value can be
based on the market value of the pasture, whether for mowing or
grazing, taking into account factors (a)–(g) above, with deductions
made for the rental value and also any costs that would be incurred by
way of application of fertilisers, sprays, pasture topping and, where
used for mowing, the harvesting costs. This will produce a value for a
season or year but percentage additions should be made for any
further years of life the pasture is estimated to have.
An alternative and possibly more accurate basis is to depreciate the
cost of establishing the ley, on an annual basis, over its term, less any
costs of spraying weeds or pasture topping, but making adjustments for
factors (a) to (g) above.

Example valuations
(i) 4 year ley (at start of second year valuation made at Candlemas Day)

per acre per ha

Cost of comparable grazing: 100.00 247.00
Summer grazing (7 months)
Winter grazing (5 months) 20.00 49.00
Expense incurred supervising stock
at away grazing say 5.00 12.00
Gross cost £125.00 £308.00

27
Agricultural Valuations

per acre per ha

Less Deductions
Rent pa 50.00 123.60
Fertilisers 22.00 54.38
Spraying/pasture topping 5.00 12.36
77.00 190.34

Net value of ley in

second year 48.00 118.65
Add for year 3 — 50% 24.00 59.32
Add for year 4 — 25% 12.00 29.66
Value of ley £84.00 £207.63

(ii) Value of same ley in its last year

(Ley due up for winter
wheat in autumn.
Valuation as at Candlemas)
Cost of comparable grazing
(7 months) (now a poorer face) 70.00 173.00

Expenses incurred supervising

stock at away grazing say 5.00 12.36
£75.00 £185.36

Less Deductions
Rent 7/12 × £50 29.00 71.65
Fertilisers 22.00 54.36
51.00 126.01
Net value of ley £24.00 £59.35

Note: some leys, near the end of their life, may have little or no value,

(iii) Value of same ley (4 year) on depreciating basis (start of second year)

per acre per ha

Cost of establishing ley say 100.00 247.10
Less: depreciation for 1 year 25.00 61.75
Value £75.00 £185.35

This is on the basis of no adjustments being made in respect of (a)-(g) above.

28
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