(concurring in the result) — I concur in the result of the opinion. The trial court should be affirmed on the principle that this court will not substitute its view of .the facts for those of the trial court when supported by *679substantial evidence. Here, on substantial but conflicting evidence, the trial court found that the assessor had fixed too high a value upon the sub j ect property.
.Beyond that, I would not go.. The case presents no more than the review of a factual dispute resolved by the superior court on disputed , evidence based largely on conflicting conclusions of expert witnesses. The learned trial judge in resolving these disputes of fact did not, I am sure, intend to abridge nor impair the responsibilities of and great weight to be accorded the county assessor, the county boards of equalization, and finally the state’s tax agencies in fixing value for tax purposes.
The hazard here, however, is that in referring to what is called functional obsolescence, the court in its opinion, may be adding a new element to the taxing methodology and require that it be specifically included and declared by the public officer charged by law with the responsibility of appraising property for purposes of assessing taxes. As I see it, the expression “functional obsolescence” is no more than one of numerous descriptive terms delineating one of many means employed by some experts in the field of real estate appraising who may take one of several available approaches in making an estimate, of fair cash market value. To hold that the assessor must ascertain whether obsolescence exists and then put a figure on it, I fear would require the assessor to spend more money in assessing commercial and industrial property than the treasurer could collect in taxes from it.
In State v. Wilson, 6 Wn. App. 443, 447, 493 P.2d 1252 (1972), the Court of Appeals stated the three basic approaches- currently employed by real estate appraisers in determining, fair market value, and pointed out that if-the cost-of-reproduction approach is utilized then a deduction should;be made for depreciation. Depreciation, the court said, includes economic and functional obsolescence. That court, I think, was speaking conceptually and did not mean to declare a rule that the assessor, the board of equaliza*680tion, or the state taxing agency must, as this court now implies, put a figure in dollars and cents upon the cost of reproduction, or upon depreciation, or upon economic obsolescence, or upon functional obsolescence, or indeed even use the cost-of-reproduction approach.
Public officials charged by the law with determining value for tax purposes may use all or none of the approaches described in State v. Wilson, supra, or a mix of some or all of them. All of these imponderables and variables are included in and a part of the concept of depreciation. See Lindheimer v. Illinois Bell Tel. Co., 292 U.S. 151, 167, 78 L. Ed. 1182, 54 S. Ct. 658 (1934) and State ex rel. Pacific Tel. & Tel. Co. v. Department of Pub. Serv., 19 Wn.2d 200, 142 P.2d 498 (1943).
One should not overlook the fact that appraising property is more of an art than a science, that it necessarily deals in imponderables and may involve wide disputes in expert opinion or judgment. Even functional obsolescence is a vague and imprecise concept, and when related to the idea of economic obsolescence it becomes even more so. Thus, a buggy whip manufacturer employing the most modern and efficient machinery designable, while not deemed functionally obsolescent in most respects, quite likely would be held economically obsolescent in all respects, and to fix a fair value upon the machinery might require the assessor to reject the idea of obsolescence altogether.
I would, therefore, while concurring in the result of this opinion, read it to hold no more than that the evidence supports the judgment and that neither the assessor nor other taxing authorities are, under existing statutes and the constitution, required to designate in dollars and cents the amount ascribed to functional or economic obsolescence, or depreciation for that matter, in arriving at the fair market value.
Utter, J., concurs with Hale, C.J.