4.4.5.2. Application to Undeveloped Land.It is rarely appropriate to apply the development method to undeveloped land.644 As a district court recently explained, the development method 

effectively values a parcel of land, even if undivided and unimproved, virtually as if it has already been subdivided and sold. Such a valuation calculation…requires more than just that a hypothetical purchaser at the time of the taking would consider development potential; it generally requires that landowner demonstrate that subdivision of the unimproved land was reasonably certain in the near future at the time of the taking.645 

Use of the development method cannot be justified based on a landowner’s “inchoate plans, intention, or profit expectations” for a property as assumptions underlying the development method are too speculative when a landowner has “not actually subdivided, improved, or sold any of the land .…”646 As the Supreme Court admonished in Olson v. United States, “allow[ing] mere speculation and conjecture to become a guide for the ascertainment of value [is] a thing to be condemned in business transactions as well as in judicial ascertainment of truth.”647 As a result, “even though the highest and best use of a property is for a residential subdivision, if no meaningful steps have been taken in that direction, viz., construction expenses and actual lot sales, then a ‘[development] method’ appraisal…would be inappropriate.”648 Rather, in such cases, “the appropriate market [is] for the entire tract as investment property for future subdivision development.”649