Footnote 1164
1164 Duncanville, 469 U.S. at 32-33; Lutheran Synod, 441 U.S. at 513-17; see Peace Arch II, 2010 WL 415244, at *2 (noting “mistaken[ ] belie [f ] that the substitute facilities doctrine deems the cost of a substitute facility to be ‘the equivalent’ of a property’s market value[,]” as “the cost of a substitute facility is an alternate measure of just compensation, it is not the equivalent of fair market value”).1165 Duncanville, 469 U.S. at 33-35; Lutheran Synod, 441 U.S. at 511, 514-16; see id. at 517-19 (White, J., concurring) (“The substitute-facilities doctrine is unrelated to fair market value and . . . unabashedly demands additional compensation over and above market value in order to allow the replacement of the condemned facility . . . . It seems to me that the argument for enhanced compensation . . . is nothing more than a particularized submission that the award should exceed fair market value because of the unique uses to which the property has been put by the condemnee or because of the unique value the property has for it.”).