Is it your interpretation of the form?
The form is not interpertable according to fannie which is why it is so ridiculous. But situationally, yes. Fannie allows two lines for "Basement and Finished areas below grade". In my opinion, that relates to A - Basement and B - areas that are below grade..quality level. So if Basement = below grade the form is redundant. why have 2 lines? I contend that it serves to allow you to adjust for basements (fin or unfin)
and any other area that is of a lesser quality or lower elevation.
Section 405.06 – Gross Living Area
the appraiser should report the basement or other partially below-grade areas separately and make appropriate adjustments for them on the "basement and finished areas below-grade" line in the "sales comparison analysis" grid. To assure consistency in the sales comparison analysis, the appraiser generally should compare above-grade areas to above-grade areas and below-grade areas to below-grade areas. The appraiser may deviate from this approach if the style of the subject property or any of the comparables does not lend itself to such comparisons. However, in such instances, he or she must explain the reason for the deviation and clearly describe the comparisons that were made.
That is Fannie's definition...please note. In some split and tri- level designs you literally would have the idiotic situation develop where the "GLA" is 100 SF or less, whereas the "below-grade" portions might be 3500 SF and the "GLA" was a foyer or entry.
Every architect, surveyor, and engineer in the world understands "grade" as ground level when referencing elevations in a set of plans. They also understand that "grade" can be more than one level in bi-level, tri-level construction. Fannie doesn't. However, they also understand "grade" as the quality level. That was true at least when i worked for an engineering firm years ago. And when a split level dwelling has two elevations of "grade" a lower and an upper level, they do not call the lower level a "basement" and if that basement serves solely to house an auto and maybe the water heater and CHA...is it a 'basement'? or a garage?
On a flat 2000 SF one story, no basement dwelling, one half being central air, heat, carpeting, finished with appliances, etc. and the other half being without plumbing, having window air and space heat with paneling nailed directly over stud walls and no insulation, you have two grades of work but the whole structure is "grade level"... One is the GLA and one is "off grade" [which can also mean construction element that is unlevel]
So...do you average the two elements to estimate the RCN of GLA? Or treat it as two elements? Likewise, are you lumping the "basement" under "basement" or under garage when the "basement" is a garage? ...and what about when the garage is a dirt floor?
As for "on grade" construction (as one pix below demonstrates) it depends upon where you call "ground level". Is it the level you walk in on? (a foyer), the level BELOW where the garage is on the same level as the den and master suite; and you walk DOWN from the foyer? or above, where you have to walk UP to the kitchen and bedrooms? Yeah, its a bad design..at least from this side of the house...it also makes a mishmash out of fannie's silly definition.
In the one pix below the entry has to be walked up to, the garage is "on grade" by engineering standards. The den/master to L is on same grade. The rest of the house has to be accessed by going up a ½ flight of stairs.
The second one is a little more complex. Again, the landing is about 5'x5' inside the entry at "grade". The lower L of house is also on same grade on slab. The entry then goes up to the midlevel where the kitchen is. To exit the kitchen you go UP to the bedrooms, or DOWN to the living room and the living room. At the entry, you can go RIGHT into an ON GRADE area that is below grade....it is lesser finish. In fact, when originally built it was the garage plus a utility. Now it is an office, den and utility. If you step out back from the utility, office, you find that you are about 2' below the ground level as is much of the rear of the house...so? is any part of the dwelling that appears to be "on grade" from front, "on grade" from the rear?
There are 3 quality levels (grades) in the dwelling. The original tri-level area; the converted garage area; and, the garage. But the only areas that are on grade by fannies definition would be the upper levels. But, in reality there is no "basement" and no dirt against a wall, etc. that would otherwise define "basement".. Basement is not a quality level and to make sensible adjustments for size, you need to count the original tri-levels and deduct somewhat for the lower "on grade" level which is "lower" grade regardless fannie's suggested way of doing it.
But that all deflects from the original purpose of my comments. In the cost approach, I am curious how you parse the cost book to arrive at defensible numbers. Again,
I am saying that the upper level (with the kitchen, bedroom, bath, and living room) is functionally comparable to the "main" level on just about every other house out here.
Then what is the issue with the basement/living area.....? It is a small house over a basement garage? It is not a Finished Room over Garage...
I am uncomfortable making up a negative adjustment for "unconventional construction"
I would be too. The Q I have is market acceptance of very small houses that appear to be unfinished mansions....I mean if this is all you are going to get, then the comparables are cabins or other small houses.
On the right hand pix below, note - rear in inset. The Left side (from front) is on wd subfloor. Most of the narrow center as well, landing in front also opens to the right into den that is on a slab foundation, level with the garage on extreme right. From the rear the foundation of the middle portion is 2' below "grade", the front is "on grade". There is a narrow level betwen the two in the rear view I didn't get marked that in the kitchen - mid level of the trilevel...