17 as the value of the property, to which the value of the eucalyptus forest plantation must be added, which according to the expert report of Rodrigo Borja Crizón,49 also presented by the representatives, has a value of US$35m3 corresponding to US$1,174,735.00 for a volume of wood of 33,563.86 m3.50 52. The expert opinion of Gonzalo Estupiñan Narváez,51 presented by the State, given both at the public hearing of October 19, 2007, as well as in the State’s briefs,52 which pointed out that the expropriated property “was never considered by Municipal Planning as an urban property or a property with the possibility of urbanization”53 and that the only possibility was an agricultural use. In this sense, the State referred, in its final arguments of November 28, 2007, the assessment process of said expert when valuating “the expropriation properties located in spaces declared of ecological protection.” Thus, the State argued that, since buildings cannot be erected on the property in question, the property of Mrs. Salvador Chiriboga should be compared with rural plots and, therefore, assessment standards for rural properties should be applied, considering their agricultural profitability, location, and quality of the soil. However, it must be taken into consideration that municipal ordinances establish an almost complete limitation on the profitable crops on land adjacent to the urban area; therefore the planting of trees is only permitted for protection and a passive recreation use. Based on these determining factors of the expert’s assessment process, the State mentioned that, given the property’s location in the city’s outskirts, it is not adequate to establish an exclusively rural value; therefore, an estimation method that also considers its urban location 295 to 296). According to the representatives, Sucres values of m2 of land in 1990 and 1991 have been converted to dollars by the expert based on the price of the Central Bank, using the averages for those years. Cf. Expert assessment of Jakeline Jaramillo Barcia, supra note 44, folios 300 and 301. 49 Cf. Expert assessment of Rodrigo Borja Crizón rendered in 2007 regarding the value of the forest (case file of reparations, tome II, folios 349 to 355). 50 According to the report “Estimation of Production,” the first objective was to determine the volume in cubic meters of eucalyptus forest. The expert estimated the area planted in 577,000 m2 once the areas of power lines and water pipes found on the property are deducted. To determine the number of trees and their development, trees were randomly sampled at six sites (plots of 5000 m2). On this basis, the expert estimated the volume of wood for the property, using the general cubic formula. In this manner, a result was gained of 33,569.86 m3. To estimate after revenue obtained from exploitation of the stand of eucalyptus, the expert presented two options: first, the sale of wood for pulping at a price of U.S. $ 35 m3, giving a total income U.S. $ 1,174,735 (price U.S. $ / m3 (35) x m3 of timber on the property (33,563.86), and on the other hand, the sale of timber processed at a price of $150, giving a total income U.S. $ 2,166,585. The expert quoted prices from SICA (case file of Reparations and Costs, tome II, folios 350 to 353). In this regard, representatives, made an application to the Court, taking into account the first alternative, which resulted in less income than the second alternative. Cf. Expert assessment of Rodrigo Borja Crizón, supra note 49, folio 245. 51 At the same time, the expert was, as of then, President of the “Ecuadorian Association of Experts,” as stated in the public hearing held on October 19, 2007 in the city of Bogotá, Colombia. 52 Cf. Expert statement rendered in the public hearing on October 19, 2007; final arguments of the State (case file of Merits, tome V, folios 809 to 814); Brief of the State related to the reparations claims (case file of Reparations and Costs, tome III, folios 574 to 581), and observations of the technical report of Jakeline Jaramilllo Barcia (case file of Reparations and Costs, tome III, folios 585 to 591). 53 The comments of Mr. Estupiñán Narváez regarding the expert report of Jake Jaramillo Barcia include other criticisms: a) he argued that the expert does not know the method based on homogenization APPRAISAL because, on the one hand, he did not compare the different characteristics of each property that is of comparable land for the purpose of assessment, and on the other hand, because “he made use of the arbitrary scale of values that is like a game of chance having reached the 0,675 coefficient,” b) he disagreed with the determination of market value, for which the expert took an average of ten offers of the developed land and multiplied it by the corresponding coefficient. He criticized the fact that the expert compared urban lands with nonurban lands, and thus considered it urbanizable for the purpose of a higher valuation and that, therefore, this calculation was “full of assumptions [...], inventions [...] and voidness,” and c) recommended that the Court seek the UPAV (Panamerican Federation of Valuation) analysis of the appraisals performed on the expropriated land “for its approach and its specialized technical comments to guide the decision [of the Court]” (case file of Reparations, tome II, folios 585 to 588).