lace of the taking, that price is just compensation." As a result, because comparable sales data were available, the Court properly held inadmissible income and replacement cost evidence (262 U.S. at 344 (emphasis added)). Only if such data are unavailable should courts resort to other methods. Furthermore, if it is necessary to resort to other methods of determining market value, courts should turn first to the income capitalization approach and then to the replacement-cost approach before resorting to historical cost valuation. Justice Brandeis used historical cost in evaluating takings challenges to con- ventional rate regulation. At no point, however, did either Justice Brandeis or the Court suggest that cost-based methodologies are superior to the comparable-sales approach under the principles of economics and fairness embodied in the Takings Clause. Instead, the Court made clear that it was sanctioning the cost-based method- ologies only because market-based methodologies were unavailable. Implicit in this argument is the recognition that the emergence of market-based benchmarks would require a return to market-based compensation principles. The foregoing analysis underscores the constitutional significance of both trans- formations that we have identified. The fundamental shift from rate regulation to access regulation makes it far easier for regulatory authorities to incorporate exter- nal reference points that reflect the demand side of the valuation equation. Because 44 Sackman (1995, § 12B.04[3], at 12B-23) calls the comparable-sales approach "the preferred way to compute market value." DeBow (1995, p. 582) states that "it is widely understood that in practice the Supreme Court shows a strong preference for the comparable sales approach." Lunney (1993, p. 728) notes that the Court "has preferred that a party establish market value through the comparable sales approach." 45 Toronto, Hamilton & Buffalo, 338 U.S. at 402; Lutheran Synod, 441 U.S. at 512-13; Duncanville Landfill, 469 U.S. at 29. The Court h