United States v. 320 Acres of Land, 605 F.2d 762, 817 n.124 (5th Cir. 1979) (“To the extent that potential uses are inconsistent or incompatible uses, whatever value the land possesses because of its suitability for each of these uses cannot be aggregated in determining fair market value and just compensation.”); United States v. Carroll, 304 F.2d 300, 306 (4th Cir. 1962); Eagle Lake Improvement Co. v. United States (Eagle Lake II), 160 F.2d 182, 184 & n.1 (5th Cir. 1947) (“It becomes manifest . . . that separate valuation [of surface rights and mineral rights] . . . would bring about confusion and injustice in condemnation cases. . . . [S]eparate awards . . . might include valuation based on inconsistent uses of the property, and consequent duplication of value.”); see, e.g., United States v. 15.00 Acres in Miss. Cty., 468 F. Supp. 310 (E.D. Ark. 1979).