See, e.g. , Ga.-Pac. , 640 F.2d at 336-37 (“The approaches to severance damages herein represent practical efforts by the parties to reach valuation determinations in a very unique and complex set of circumstances.”); but see United States v. 33.92356 Acres of Land (Piza-Blondet ), 585 F.3d 1, 9 (1st Cir. 2009) (refusing alternative valuation method when there was “no persuasive reason why the before and after method would be unfair in assessing the value” in a partial taking).