From the Fith Amendment: "...nor shall private property be taken for public use, without just compensation."
The Supremes have affirmed that "public use" is an unqualified term in the context of the amendment and, therefore, anyone seeking to take land needs no qualifiers as long as they can make a claim to "public use", however tenuous.
I take this opportunity to point out that "just compensation" is a likewise unqualified term in the context of the same amendment and, therefore, anyone having their property taken has every iota of freedom to define "just compensation" as the freedom the Court has now affirmed for defining the term "public use".