Disagree. If I don't believe some particular research, or approach to value, is necessary for credible results, I DO NOT HAVE TO PERFORM THAT TASK, and it absolutely IS an appropriate 'out' (to use your words). I am responsible for developing my SOW, not the intended user. And, at least in the case of agency work, neither the agencies, nor the investors, nor the lender, nor the borrower care whether the cost approach has been developed or not (sans the prior example of some lenders requiring it for insurance purposes).