Footnote 1107

1107 In partial acquisitions (Section 4.6), the measure of compensation is normally the difference between the market value of the landowner’s property before and after the government’s acquisition. E.g., United States v. Birnbach, 400 F.2d 378, 382 (8th Cir. 1968). Appraisers therefore apply the before and after valuation method (the Federal Rule), estimating the market value of the larger parcel before the acquisition, and subtracting the market value of the remainder property after acquisition, to determine the difference (diminution) in market value. See Section 4.6.1.1108 Cf. Birnbach, 400 F.2d at 382-83 (holding that in determining damage to remainder property in partial taking affected by navigational servitude, an “important distinction must be made so that the enhancement in value ‘flowing’ from a riparian location may not be recognized when the riparian character of the [remainder] land is destroyed”). While Birnbach predated § 595a, the statute did not change the compensation for damage to remainder property. See Pete, 447 F.2d at 770-71 (discussing Birnbach and § 595a).