See United States ex rel. Tenn. Valley Auth. v. An Easement & Right-of-Way over 6.09 Acres of Land (TVA v. 6.09 Acres), 140 F. Supp. 3d 1218, 1250-51 (N.D. Ala. 2015) (citing cases); compare United States v. 99.66 Acres of Land (Sunburst Invs.), 970 F.2d 651, 655-56 (9th Cir. 1992) (affirming exclusion of method for valuation of “paper subdivision and nothing more”) and United States v. 100 Acres of Land, 468 F.2d 1261, 1266-67 (9th Cir. 1972) (permitting method for valuation of property which was part of a subdivision that was partially under development on date of value).