that bears no necessary relationship with present value. As a result, historical cost is often a backward-looking measure that is unreliable in determining a current fair market value (338 U.S. at 403). Moreover, the Court in Olson pointed out that mar- ket value "may be more or less than the owner's investment. He may have acquired the property for less than its worth or he may have paid a speculative and exorbitant price. Its value may have changed substantially while held by him The public application of these principles in the telecommunications context, see Illinois Bell, 988 F.2d at 1262-63. See, e.g., Toronto, Hamilton & Buffalo, 338 U.S. at 398-403 (finding that development of new ferry routes rendered earnings records of prior years' routes unreliable indicators of future income). See Sackman (1995). See, e.g., Toronto, Hamilton & Buffalo, 338 U.S. at 403. See Duncanville Landfill, 469 U.S. 24 at 34-35. The Court's criticism of historical-cost methodologies dates back to its earliest takings decisions. See, e.g., Monongahela, 148 U.S. at 328 ("The value, therefore, is not determined by the mere cost of construction. Networks in Telecommunications may not by any means confiscate the benefits, or be required to bear the burden, of the owner's bargain He must be made whole but is not entitled to more" (292 U.S. at 255; accord Sackman 1995). Because of the problems associated with these other methodologies, the Court has consistently indicated that the comparable-sales approach represents the best evidence of market value. 44 Indeed, the Court has gone SO far as to characterize other valuation methods, including replacement cost, as exceptions to the comparable- sales approach and to hold them inapplicable whenever there are market-based transactions in similar properties. 45 The Court offered its most dramatic statement to this effect in United States V. New River Collieries Co., in which it held that "[w]here private property is taken for public use, and there is a market price prevailing at the time and p