Appeal No. VA94/3/011

AN BINSE LUACHÁLA
VALUATION TRIBUNAL
AN tACHT LUACHÁLA, 1988
VALUATION ACT, 1988

Shelbourne Greyhound Stadium Limited APPELLANT
and
Commissioner of Valuation RESPONDENT

RE: Stadium at Map Ref: 43a, South Lotts Road, Ward: Pembroke West A, County Borough of Dublin
Quantum - Attendances, Trading accounts, economic reality

B E F O R E
Con Guiney - Barrister at Law Deputy Chairman
Barry Smyth - FRICS.FSCS Member
Ann Hargaden - FRICS.FSCS Member

JUDGMENT OF THE VALUATION TRIBUNAL
ISSUED ON THE 28TH DAY OF OCTOBER, 1998

By Notice of Appeal dated the 21st October 1994 the appellant appealed against the determination of the Commissioner of Valuation in fixing a rateable valuation of £1,000 on the above described hereditament.

The grounds of appeal as set out in the said Notice of Appeal are that:
"1. The valuation is excessive and inequitable.
2. The valuation is bad in law".

The appeal was determined by the Tribunal on the 18th May 1995. The decision affirming the Commissioner's valuation was appealed by way of a case stated to the High Court and was remitted to the Tribunal for re-hearing. The appeal proceeded to hearing on the 4th September 1998.

The Appellant was represented by Mr. Maurice Gaffney, S.C. instructed by Mr. Tom McGrath, Solicitor of T.P. Robinson & Co. Mr. Alan McMillan ARICS, an Associate of the Society of Chartered Surveyors and a Director of Donal O'Buachalla & Company Ltd., gave evidence. Mr. McMillan was accompanied by Mr. Noel Hynes, General Manager of Shelbourne Greyhound Stadium Ltd., who also gave evidence to the Tribunal. The Respondent was represented by Mr. Eamonn Marray, B.L. instructed by the Chief State Solicitor. Mr. Peter Conroy, District Valuer in the Valuation Office with 25 years experience in rateable valuations also gave evidence.

A mention of the matter took place before the Chairman of the Valuation Tribunal on the 27th April 1998 where it was agreed between the parties that the written submissions as originally submitted would be used for the purposes of this oral hearing.

Valuation History
1928 RV £300
1931 RV £340
1952 RV £1,050
1965 RV £1,225
1969 RV £1,000
1970 RV £1,750 - reduced to £1,200 on appeal
1981 RV £1,300 - reduced to £1,255 on appeal
1986 RV £1,255 - no change reduced to £1,055 on appeal
1986 Circuit Court Appeal No. 97 - not yet heard.
1993 RV reduced to current £1,000

Material Facts

The Property

Description
The hereditament comprises a Greyhound Racing Stadium together with flood-lit running track, viewing stand and ancillary service building and car park.
Part of the property is occupied by Bord na gCon as Totelisator Offices which is valued separately and is not the subject of this appeal. The race track is exempt. The total site area to include the race track is approximately 8.3 acres and the track is enclosed by a one metre high concrete perimeter wall.

Location
The property is located in Ringsend on South Lotts Road close to the intersection with Ringsend Road and approximately 1.5 miles southeast of Dublin city centre. It is bounded to the north by Heitons, to the south by the ESB Sports Complex and Depot and to the east by the River Dodder. The main entrance is located at the northern end of the South Lotts frontage and comprises a recessed vehicular access with adjacent pedestrian/turnstile access.

Accommodation
1. "NEW STAND" - (Nominal Capacity - 5,000)
The accommodation includes:

Ground Floor
Concourse with bar, snack bar and tote facilities, stairwell and lift. (toilets on mezzanine floor)
7634 Sq. Ft.
710 Sq. M.
Open viewing terrace
6542 Sq.Ft.
608 Sq. M.

First Floor
Concourse bar (with access from terrace), tote windows and 2 suites - ("Derby" and "Champion Stakes")
4874 Sq. Ft.
453 Sq. M.

Second Floor

Lounge and rooms (VIP, Camera, Judges, Press, Hare Driver) and toilets
5670 Sq. Ft.
527 Sq. M.

Sub-Total
24720 Sq. Ft.
2296 Sq. M.

(a) Stand Extension
During 1990/1 an extension was constructed to the rear of the stand providing additional accommodation at:

Ground floor:
Hall, stairs, toilets and turnstiles/lobby.
2418 Sq. Ft.
225 Sq. M.

First floor:
Bar, lounge extension, additional tote area and toilets.
1934 Sq. Ft.
180 Sq. M.

Second floor:
Plant Rooms - Not available to public, shell finish
1934 Sq. Ft.
180 Sq. M.

Sub total :
6286 Sq. Ft.
585 Sq. M.

[NOTE: Part of this accommodation was unfitted at November 1993].

(b) Stand Conservatory
Also in 1991 a small conservatory lobby was added to the eastern end of the ground floor concourse.
790 Sq. Ft.
73 Sq. M.

Sub Total:
31796 Sq. Ft.
2956 Sq. M.

2. OFFICES

Office buildings including bar and restaurant
4767 Sq. Ft.
443 Sq. M.

3. TURNSTILES
516 Sq. Ft.
48 Sq. M.

4. KENNEL AREA
a) Racing and sales kennels (plus canopies)
4788 Sq. Ft.
445 Sq. M.
b) Weighroom, vet's room and staff area
710 Sq. Ft.
66 Sq. M.
c) Store
495 Sq. Ft.
46 Sq. M.
d) Toilets

Sub-total
5993 Sq. Ft.
557 Sq. M.

5. HARE TOWER AREA
925 Sq. Ft.
86 Sq. M.

Miscellaneous
i) Switch room
ii) Boiler house
iii) Pump house
299 Sq. Ft.
28 Sq. M.

Sub-total
1,224 Sq. Ft.
114 Sq. M.

6. BOOKMAKERS PITCH
Sub-total
2,690 Sq. Ft.
250 Sq. M.

GRAND TOTAL
46,986 Sq. Ft.
4,365 Sq. M.

7. CAR PARKING AREA
44,966 Sq. Ft.
4,177 Sq. M.

Submissions of the Parties at the Hearing
Mr. Gaffney, on behalf of the Appellant, outlined the history of the Greyhound Stadium. He indicated that the stadium was erected in the 1920's. The business was conducted with reasonable success for many years and the receipts belonged to the owners. In 1958 the Greyhound Industry substantially changed when Bord na gCon was established - this Bord was entitled to license stadia. They acquired Shelbourne Stadium from the owners and Shelbourne Stadium Ltd was set up, a wholly owned subsidiary of Bord na gCon. This body was entitled to the tote betting revenues. Mr. Gaffney then pointed out that between 1980 and 1993 the tote turnover and attendances decreased by 64% and that between 1990 and 1993 there was an escalation of losses and the company set up a commission of enquiry which established that the sport was declining. He referred to the Punchestown Racecourse case (VA93/3/035) and quoted the findings of the Tribunal where it was stated that in assessing the NAV of any racecourse it is difficult to ignore economic reality. He also referred to another decision of the Tribunal in the National Basketball Arena case (VA94/2/041) where the RV was assessed at £300.00 or £1.60 psf overall.

The comparisons situated at Cork and Limerick which were assessed at £220.00 and £160.00 respectively were also mentioned. He stated that these were agreed figures.

Mr. Alan McMillan was then called and gave a brief background to the development of the Shelbourne Greyhound Stadium and its valuation history. He referred to his written submission and stated that in arriving at a fair valuation, he had examined the following issues.
A. Attendances
B. Tote Figures
C. Operating profit / loss
D. Revenue

He said that attendances had been in rapid decline for the past 15 years. Specifically he said the overall reduction from 1980 to 1993 was 64%. In relation to the Tote he said that the total turnover had shown a reduction from £3.87 million to £1.353 million over the same period, that is, a 64% drop. Under operating Profit and Loss he said that net losses for the four years up to the statutory valuation date were as follows:
1990 £44,104
1991 £86,303
1992 £115,590
1993 £127,004

Mr Mc Millan said that this contrasts with a pattern of consistent if modest, profits for many years up to 1988. In relation to revenue, Mr Mc Millan said that the accounts showed a decline in real terms of 42% from 1980 to 1993.

Mr McMillan stated that he had adopted the trading approach in an effort to demonstrate the decline in this sport and to reflect that there were technically no funds available for rent and rates and that it was evident that a material diminution in beneficial and rateable occupation, due to circumstances beyond the control of the appellant, resulted in the RV at issue being now and for some years past excessive and inequitable. Mr Mc Millan set out his valuation on a number of bases which are summarised in the Appendix.

In analysing the trading accounts he stated that he was not suggesting that the property was not capable of beneficial occupation and not rateable but suggesting that a hypothetical tenant would pay rent but his opinion would be strongly influenced by the financial status of the company.

Mr. McMillan used two comparisons, the Greyhound Stadia in Cork and Limerick. He stated that when the NAV was assessed on both tracks they were profitable entities. Both were assessed at a total RV of £380. They had the same attendance jointly as Shelbourne Park at the time but they accommodated 73% of the overall floor area in Shelbourne Park. The average rate per square foot in Cork was £2.30 and the average rate per square foot in Limerick was £1.28 whereas the RV proposed on Shelbourne Park is £3.50 per sq.ft overall.

Mr McMillan was then cross examined by Mr. Marray. He stated that Cork had a brand new stand at the time of his assessment and would have been superior to Shelbourne Park whereas Limerick would have been inferior. Mr. Marray stated that Shelbourne stadium was perhaps the flagship of the racing industry whereupon Mr McMillan stated that it was the largest. When questioned about the market value at the time, Mr.Millan said he would regard it as a high value area if it was taken to be an apartment development site. However, this potential had to be disregarded for the purposes of NAV.

He stated that he was relying on his comparisons and that he had reduced the overall rate on Shelbourne Park to reflect the size of the stadium as it was at least three times the size of Cork and Limerick. He accepted that the most valid approach would be the comparative method but that the backdrop must be the trading figures. He also stated that in assessing NAV he had allowed for the car parking in the overall rate adopted. He indicated that there were approximately 150 cars and that on race nights, a charge of 50p per car was levied.

Other comparisons were mentioned including the ESB Sports Complex premises adjacent. This premises was described as a completely different building. It was also indicated that Punchestown Racecourse was used as a guide. It was confirmed that it was in a rural area and that the analysis used was not the analysis of the Tribunal. Mr McMillan also stated that he would not place much reliance on the National Basketball Arena. He also stated that the analysis of the Cork stadium was not agreed.

Mr Hynes, General Manager of Shelbourne Stadium, then gave evidence. Mr Hynes indicated that he had only commenced as manager in 1993 whereupon he carried out market research. He stated that Shelbourne Stadium was the biggest of a bad lot and that the investment of £1 million only allowed a minimal upgrade and that the facility was appallingly poor. When asked whether there were any facts available to a hypothetical tenant which would give hope, he stated that the decline was really evident in the U.K. and was mirrored in Ireland where the market place held other attractions.

Mr. Marray then cross examined Mr. Hynes who confirmed that the lack of investment caused some of the decline as the facilities were poor and it was difficult to attract customers. The industry survived on grants every year and it was hard to run the business. Bord na gCon wanted to keep the track going because of the breeding industry which employs over 20,000 people in Ireland. He stated that the Revenue from exports in 1993 was not available. He also stated that the property was held by Bord na gCon under a sporting lease from Pembroke Estates which restricted the use of the facility to sporting use.

Mr. Peter Conroy, District Valuer, then gave evidence and outlined the facts briefly described in his written submission, including the property, its location, and accommodation. In Mr Conroy's written submission, he pointed out that Bord na gCon was statutorily funded by:
a) 5% levy on bookmaker's gross turnover
b) A monopoly of the Revenue from all Totes at tracks.

In exchange for the cash the Bord receives, the Bord distributes grants towards prize money and development costs. Shelbourne Greyhound Stadium Ltd is a wholly owned subsidiary of Bord na gCon. It holds the stadium without paying a rent or dividend. It has a drink licence, regulated by the Act. The only source of income is gate receipts, which are controlled by the Bord, catering profits, car parking fees, trials charges, sales commissions and grants.

Mr Conroy stated that the involvement of the Bord in tracks, as an overall development agency for the industry, is a complicating factor. If all tracks were to survive unaided, only a few would survive, and as one closed, the viability of others would be enhanced. He stated that the low profits could be due to Bord policy and that losses made at the Stadium could be recouped by profits elsewhere in the industry. He stated that the location of this property was prime, close to the city centre and that although the buildings were old they served their purpose adequately. He approached the valuation on a traditional unit price using Cork and Limerick as comparisons but reflecting a premium for Dublin. He stated that Mr. McMillan's rates were low and he disagreed with a reduction for quantum. He had looked at the accounts and confirmed that they were of no assistance in assessing the NAV of the building but rather in assessing the business viability. He stated that Punchestown Racecourse as a comparison was put in as a guide and that Mr. McMillan's rates should be higher than this course as this is a rural area and should not be compared to Dublin. He also referred to the ESB Sports Complex. He stated that he had used a capital value as a function of rent and deduced from that what a rent could be. He accepted that the improvements completed did not greatly enhance the value.

Mr. Gaffney then cross examined Mr. Conroy. Mr. Conroy stated that if the property were to be put on the market on the basis that it was to be run as a greyhound stadium it would affect capital value and agreed that it has to be taken as is. He estimated the capital value at £2.5m and in 1993 at a yield of 6.5% this would give an NAV of c. £162,500 p.a. He indicated that there was some confusion about the car park and that he thought there were approximately 250 spaces as there was in excess of 50,000 sq. ft. on site. He accepted that the spaces currently in use amounted to c. 180. Mr. Gaffney stated that the sporting lease requires a greyhound racing use and any deviation from that will not be acceptable to the landlord and that the property has to be devoted to sport. In that context, there would be no question of the car parking being leased out to the public as this would be a use for commerce and not for sport. Mr. Conroy stated nonetheless that the yard was of value and he did not think that Mr. McMillan had reflected this in his rates. He stated that the capital value of £2.5 m was modest in 1993. Mr. Conroy then referred to his comparative approach, he stated in relation to the Cork Stadium that his analysis was obtained from the old valuation file but that it was not agreed.

Mr. Marray then summarised and asked that the Tribunal have regard to the decision made in Trustees of Fitzgerald Memorial Park -v- Commissioner of Valuation VA95/1/001. He stated that the approach adopted supported the reasoning that where comparative evidence was available it must be regarded as the most appropriate approach. Mr. Gaffney then submitted that comparative evidence is the most compelling evidence and that the assessment of £3.50 psf overall on Shelbourne Stadium is way in excess of Cork and Limerick at £2.30 psf and £1.28 psf respectively and that the economic factors submitted were mentioned only as an indicator.

Determination
The evidence submitted indicated that Bord na gCon is in existence to promote and ensure the continuance of the sport of greyhound racing and that the running of the stadium is very much dictated by the Bord and this was the system operating in 1993. The assessments on both Cork and Limerick appear to have been completed under the old rating system. The NAV's were also assessed when trading conditions were better. These comparisons however are compelling when one considers that the attendances are exactly the same together as that of Shelbourne Park, even though the area is significantly less. The Tribunal accepts the evidence in relation to trading accounts submitted by the appellant and agrees that these are a reflection of the viability of the business rather than of assistance in assessing the NAV of the building. We are of the opinion, however, that the hypothetical tenant's views will be coloured by the existence of these trading figures and that economic reality must be taken into account in assessing the NAV. There are however, economies of scale in running one stadium as opposed to two and in these circumstances the Tribunal determines the rateable valuation at £682.00 as follows:-

SCHEDULE OF SUBMITTED AREAS AND PRICES PER SQUARE FOOT

Concourse 7,634 sq.ft. @ £3.00 = £22,902
Terraces 6,542 sq.ft. @ £1.00 = £ 6,542
Bar 4,874 sq.ft. @ £4.00 = £19,496
Judges, Press, VIPs etc.. 5,670 sq.ft. @ £2.00 = £11,340
Toilets 1,030 sq.ft. @ £1.00 = £ 1,030
New Conservatory 802 sq.ft. @ £1.25 = £ 1,002.50
Recent Ext. (3 floors) 6,286 sq.ft. @ £2.50 = £15,715
Office Buildings (Inc. Bar and Restaurant) 4,767 sq.ft. @ £3.50 = £16,684.50
Turnstiles }
Kennel Area }
Tower Area }
Sub-Total } 7,733 sq.ft. @ £1.00 = £ 7,733
Bookmakers Pitch 2,690 sq.ft. @ £0.50 = £ 1,345


TOTAL 48,075 sq.ft. £103,790.00

Car Park Area 44,966sq.ft. @ £0.10 = £ 4,496.60

Total NAV £108,286.60 @ 0.63% = £682.20 SAY £682.00