The BHA response to the consultation – Reforming the Non-Domestic rates appeals system in Wales (2018)

Reforming the Non-Domestic rates appeals system in Wales
Page 1: Submit your response

1. If you agree that the appeals process can be improved, which aspects of the system do you think could be improved and how?

The hydropower sector has experienced a rating methodology that is clearly colossally unfair and inappropriate and a fundamental review of the overall methodology is urgently required to be undertaken by Welsh Government.  The appeals process as laid out does not allow an appellant to make appeal based on the rating not necessarily being wrongly calculated, but through the VOA using a methodology with which the VOA are satisfied, but industry believes is flawed, creating wholly unacceptably high RVs which in many cases are jeopardising the future viability of some hydropower schemes in Wales.  The appeals process must include a section where an appellant can lodge an appeal against the valuation method not just the individual valuation level. We propose that there is a new process included where the individual Valuer from the VOA can be reported to the RICS if there is dissatisfaction with the professional competence of the valuation.

2. What are your views on ratepayers being required to register their property or properties before initiating the appeals process?

The BHA agrees that the appellant must register before initiating any stage of the appeals process. Agents can continue to act on behalf of an appellant once the appellant has registered.

3. How do you think ratepayers should be able to declare their interest in a property?

By the ratepayer referring the VOA to the Land Registry for England and Wales

4. What are your views on introducing time-limits for different stages of the appeals process?

Do you think the suggested time-limits are appropriate? What do you think would be appropriate time-limits? The BHA agrees in principle with a 12-month time frame for the VTW to deal with an appeal, though with the caveat of ‘time not of the essence’ as far as the appellant is concerned.

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