TVA v. 6.09 Acres , 140 F. Supp. 3d at 1255; see generally id. at 1247-56. Courts express similar concerns outside federal condemnation. E.g., United States v. Hickey , 360 F.2d 127, 137 (7th Cir. 1966) (“Whatever its merit to builders and developers might be, the speculative and unrealistic character of ‘lot-method’ appraisals in assessing the value of vacant land as security for mortgage loans is apparent. ‘Lot-method’ appraisal is a reflection