1111 See United States v. Va. Elec. & Power Co., 365 U.S. 624, 629-30 (1961) (remanding for determination of “depreciative impact of the [acquisition] upon the nonriparian uses of the property”).1112 United States v. Rands, 389 U.S. 121, 125-26 (1967); United States v. River Rouge Improvement Co., 269 U.S. 411, 417-18 (1926); see 33 U.S.C. § 595 (2012) (mandating that in partial takings in connection with improvement of rivers, harbors, canals or waterways of the United States, award of just compensation “shall take into consideration by way of reducing the amount of compensation or damages any special and direct benefits to the remainder arising from the improvement”); see also United States v. Eastman (Eastman I), 528 F. Supp. 1177, 1179 n.2 (D. Or. 1981), adopted 714 F.2d 76, 77 (9th Cir. 1983) (per curiam) (“Where only part of a tract of land is taken, the government is entitled to deduct from the condemnation award benefits which accrue to the landowner’s remaining land in the same tract.” (citing § 595)).