through cash flow analysis, the current price a developer-purchaser would be warranted in paying for the land, given the cost of developing it and the probable proceeds from the sale of developed sites. Ramsey Co. v. Miller, 316 N.W.2d 917, 920 (Minn. 1982), quoted in Port Auth. of St. Paul v. Englund, 464 N.W.2d 745, 748 (Minn.App. 1991). Hansen was prepared to testify that the improvement would benefit the property only if the property were developed.
We have previously interpreted the third prong of the Miller test-that development is not too remote-to require a showing that development is imminent. Port Auth. of City of St. Paul v. Englund, 464 N.W.2d 745, 749 (Minn.App. 1991).
When the condemnor and the landowner agree upon the highest and best use of the land, the landowner's plans for future development are irrelevant to the issue of fair market value. See Port Authority v. Englund, 464 N.W.2d 745, 750 (Minn. App. 1991) (holding that consideration of evidence of a landowner's particular plans for development is allowed only for the limited purpose of establishing the highest and best use of the property). See also United States v. Miller, 317 U.S. 369, 374-75, 63 S.Ct. 275, 280 (1943) (holding "that fair market value does not include the special value of property to the owner arising from its adaptability to his particular use"). Conversely, if highest and best use is genuinely in dispute, that is, through admissible evidence reasonably supporting contrary conclusions, there is authority that such plans are relevant and admissible.
The development-cost method can be applied to an already developed urban, commercial facility. Port Auth. of the City of St. Paul v. Englund, 464 N.W.2d 745, 748-49 (Minn.App. 1991). Because the development-cost approach is complex and susceptible to manipulation, "it should be employed judiciously, when the other traditional methods for valuing property are not wholly reliable and only after a proper foundation has been laid."