I suggest that you stick to the one complaint – that the comparables are fictitious. This is by far the most serious ‘error’. I agree with all your points, but point out that the valuer will not have had the time to go into the very local market in as much detail as you. However, its bosh that orientation does not affect value. Check that the valuer’s valuation is before or after the banks costs i.e. has he/she deducted agency fees, etc. before giving the value. 10% off would account for that.