Footnote 758

760.807 Acres in Honolulu, 731 F.2d at 1448; Hendler v. United States, 175 F.3d 1374, 1384-85 (Fed. Cir. 1999) (affirming finding that diminution in market value of contaminated property was due to preexisting contamination caused by third parties, not government’s subsequent remediation activities). Proof of causation is also required to consider the effects of the government project in total acquisitions. See, e.g., United States v. 1.604 Acres of Land (Granby I), 844 F. Supp. 2d 668, 675-76 (E.D. Va. 2011) (“[The court] need not resolve [project influence issues] because there is scant evidence that the government’s actions actually affected the market value of the property.”).