This article talks about the substantial distinction between a physical government invasion and a coercive request for funds, if the government action fails under Nollan and Dolan. Clearly, there is a newly recognized risk to water resource regulators who try to stop development in areas which are considered wetlands.
Colin W. Maguire,
Alito's Voice: Koontz and the end of Justice Steven's Private Private Property Regulation Policy,
63 Clev. St. L. Rev.
available at https://engagedscholarship.csuohio.edu/clevstlrev/vol63/iss4/6