1021 In contrast, direct acquisitions, while often voluntary, may involve at least a possibility that the government can exercise the power of eminent domain to take property for a public purpose with payment of just compensation.1022 E.g., Greer Coal., Inc. v. U.S. Forest Serv., 470 F. App’x 630 (9th Cir. 2012) (unpubl.); Nat’l Parks & Conservation Ass’n v. Bureau of Land Mgmt. (NPCAv. BLM), 606 F.3d 1058 (9th Cir. 2010); Desert Citizens Against Pollution v. Bisson, 231 F.3d 1172 (9th Cir. 2000). Litigation also arises over the