Footnote 851
Ga.-Pac. , 640 F.2d at 337; see United States ex rel. Tenn. Valley Auth. v. Robertson , 354 F.2d 877, 880-81 (5th Cir. 1966) (“[Elements] which make the property less desirable and thus diminish the market value of the property are proper to be considered, though as a separate item of damage might be too speculative and conjectural to be submitted ”); see also United States v. Honolulu Plantation Co. , 182 F.2d 172, 179 (9th Cir.