Ask any contractor or new home builder if below grade is equal to above grade in cost and quality.
That's a fact. It costs a lot less to build a hole in the ground with concrete around it than it does to build above ground space. Finish could be equal, cost to construct will still be less.
Another important issue is functionality.
Below grade space rarely has the same functionality as above grade space. The floor plan and layout of the below grade space is hampered by lack of exit doors, and in the case of walk-outs it is hampered by exit doors on only one side (usually). I know that there are exceptions, but typically, the below grade space is has at least one large area without a rectangular shape that is best used as a rec room.
What realtors see it as in the market is not the same as what appraiers see it as in many cases. That is why comments about how it is "marketed" are of some concern.
Still, I think there are exceptions and there might be
some cases where it is acceptable to put it all together. The most common exception in this area is berm construction. Even though it is technically below-grade, most realtors
and most appraisers in this market count it as GLA.
I would be very sceptical of a claim that
all below grade space is marketed as living area and always counted together with GLA. Remember that I live in a nono-disclosure state. Our MLS didn't used to separate it out very well either. And, our assessors office is only slightly better than a glass eye for such things. Still, back in the days before we finally convinced the MLS, appraisers typically did it right. It's harder work, but usually is possible.