9); Gulf Power Co. V. FCC, 208 F.3d 1263, 1272-73 (11th Cir. 2000), rev'd on other grounds sub nom. Nat'l Cable & Telecomms. Ass'n V. Gulf Power Co., 524 U.S. 327, 342 (2002). 22 United States V. 564.54 Acres of Land, 441 U.S. 506, 510 (1979) ("Lutheran Synod"), quoting Olson V. United States, 292 U.S. 246, 255 (1934). As Richard Epstein (1985, p. 182) has noted, "In principle, the ideal solution is to leave the individual owner in a position of indifference between the taking by the government and the retention of the property." For other early statements of this principle, see Monongahela, 148 U.S. at 326, and Seaboard Air Line Railway Co. V. United States, 261 U.S. 299, 304 (1923). 23 See also New River Collieries, 262 U.S. at 344; Olson, 292 U.S. at 255; United States V. Miller, 317 U.S. 369, 374 (1943); Gen. Motors, 323 U.S. at 379; United States V. Commodities Trading Corp., 339 U.S. 121, 123 (1950); Almota Farmers Elevator & Warehouse Co. V. United States, 409 U.S. 470,474 (1973); Lutheran Synod, 441 U.S. at 511; Kirby Forest Indus. V. United States, 467 U.S. 1, 10 (1984); United States V. 50 Acres of Land, 469 U.S. 24, 29 (1984) ("Duncanville Landfill"). Although the cases at times refer to this standard as "fair market value," as the Court noted in Miller, the two formulations essentially amount to the same thing (317 U.S. at 374). Constitutional Limits on the Pricing of Access to Networks (Monongahela, 148 U.S. at 326, 328, 329). The Court reaffirmed this principle on numerous occasions (see, e.g., Lucas, 505 U.S. at 1017; Kimball Laundry, 338 U.S. at 9). Practical considerations provide additional reasons for preferring exchange- oriented approaches over cost-oriented approaches when determining just com- pensation. As the Court observed, the shift to the market-value standard was driven in part by the "need for a clear, easily administrable rule governing the measure of 'just compensation." The use of external measures of value eliminated many of the "serious practical difficulties in assessing the wo