See TVA v. 6.09 Acres, 140 F. Supp. 3d at 1247-56; Sunburst Invs., 970 F.2d at 655-56; eATon, supra note 16, at 246 (“[I]n many cases the development approach has been applied under the wrong circumstances or in the wrong way. If all of the land that has been appraised by the development approach were actually subdivided, there would be enough subdivision lots on the market to last hundreds of years and little, if any, farmland left in the United States.”).