s, which affect only the property-use strand, physical invasions "chop [ ] through the bundle, taking a slice of every strand." Specifically, physical occupations necessarily foreclose owners from either possessing or using the occupied portion of property. Although the owner retains the theoretical right to dispose of the occupied space, the presence of equipment attached to that space essentially "empt[ies] the right of any value." In addition, the Court concluded that these deprivations are particularly severe when the gov- ernment authorizes a stranger to invade and occupy the owner's property. As a result, the Court concluded that a permanent physical occupation "is qualitatively more severe than a regulation of the use of property, even a regulation that imposes affirmative duties on the owner, since the owner may have no control over the timing, extent, or nature of the invasion" (Loretto, 458 U.S. at 435, 436, 441). Finally, the Court invoked practical considerations. Treating permanent physi- cal occupations as per se takings "avoids otherwise difficult line-drawing problems." Unlike the ad hoc quality of the Penn Central balancing test, determining the pres- ence of a permanent physical occupation under Loretto poses fewer problems of proof. For example, "[t]he placement of a fixed structure on land or real property is an obvious fact that will rarely be subject to dispute." As a result, when the government action is in the form of a permanent physical occupation, that factor by itself becomes "determinative." Although the size and economic impact of the occupation are relevant in ascertaining the amount of compensation, those con- siderations play no role in determining whether a taking has occurred (Loretto, 458 U.S. at 434-35, 436-38). 9 The Court reasoned that nothing in Penn Central "repudiate[s] the rule that a permanent physical occupation is a government action of such a unique character that it is a taking without regard to other factors that a court might ordinarily examine." The Court emphasi