Natl Assn Mftr v. DOI

                        United States Court of Appeals


                     FOR THE DISTRICT OF COLUMBIA CIRCUIT


              Argued December 5, 1997 Decided January 16, 1998 


                                 No. 96-1268


                   National Association of Manufacturers, 

                                  Petitioner


                                      v.


                  United States Department of the Interior, 

                                  Respondent


                  On Petition for Review of an Order of the 

                   United States Department of the Interior


     James R. Bieke argued the cause for the petitioner.  Wil-
liam R. Galeota and Jan Amundson were on brief.

     Greer S. Goldman, Attorney, United States Department of 
Justice, argued the cause for the respondent.  Lois J. Schif-
fer, Assistant Attorney General, and Naikang Tsao, Attorney, 
were on brief.



     Before:  Ginsburg, Henderson and Tatel, Circuit Judges.

     Opinion for the court filed by Circuit Judge Henderson.

     Karen LeCraft Henderson, Circuit Judge:  The Compre-
hensive Environmental Response, Compensation, and Liabili-
ty Act of 1980, as amended, 42 U.S.C. ss 9601 et seq., 
(CERCLA) permits a "trustee" 1 to recover from a "potential-
ly responsible party" (PRP) 2 "damages for injury to, destruc-
tion of, or loss of natural resources, including the reasonable 
costs of assessing such injury, destruction, or loss resulting 
from ... a release" of a hazardous substance regulated under 
CERCLA.  42 U.S.C. s 9607(a)(C).  Subsection 301(c)(1) of 
CERCLA, directs the President (acting through his designee, 
the Secretary of the United States Department of Interior) to 
promulgate regulations that "specify ... standard procedures 
for simplified assessments [of natural resource damages] 
requiring minimal field observation, including establishing 
measures of damages based on units of discharge or release 
or units of affected area."  42 U.S.C. s 9651(c).  A damage 
________
     1 A "trustee" is a federal, state or Indian tribal official who, in 
accordance with 42 U.S.C. s 9607(f)(2), is designated to "act on 
behalf of the public as [a] trustee[ ] for natural resources."

     2 Under CERCLA, a PRP is:

     (1) the owner and operator of a vessel or a facility,

     (2) any person who at the time of disposal of any hazardous 
     substance owned or operated any facility at which such hazard-
     ous substances were disposed of,

     (3) any person who by contract, agreement, or otherwise ar-
     ranged with a transporter for transport for disposal or treat-
     ment, of hazardous substances owned or possessed by such 
     person, by any other party or entity, at any facility or incinera-
     tion vessel owned or operated by another party or entity and 
     containing such hazardous substances, and

     (4) any person who accepts or accepted any hazardous sub-
     stances for transport to disposal or treatment facilities, inciner-
     ation vessels or sites selected by such person, from which there 
     is a release, or a threatened release which causes the incur-
     rence of response costs, of a hazardous substance, ...

42 U.S.C. s 9607(a).



assessment performed according to these procedures is enti-
tled to "the force and effect of a rebuttable presumption ... 
in any administrative or judicial proceeding."  42 U.S.C. 
s 9607(f)(2)(C).

     This is a challenge to the final rule of the Department of 
the Interior (DOI), entitled "Natural Resource Damage As-
sessments--Type A Procedures," 61 Fed. Reg. 20,560 (1996) 
(codified at 43 C.F.R. pt. 11) (hereinafter 1996 Type A rule), 
that partially implements CERCLA section 301(c), 42 U.S.C. 
s 9651(c).  The petitioner, National Association of Manufac-
turers (NAM), claims that the Type A final rule violates 
CERCLA and the Administrative Procedure Act, 5 U.S.C. 
ss 551 et seq., (APA), and therefore must be vacated for one 
or more of the following reasons:  (1) the rule permits dam-
ages to be calculated without on-site verification that a natu-
ral resource has in fact been injured and that the injury is in 
fact attributable to the particular release in question; (2) the 
rule does not require a trustee to consider, in calculating 
natural resource damage (NRD), an alternative to restoration 
of an adversely affected resource (i.e., replacing a damaged 
resource or acquiring its equivalent); (3) the rule arbitrarily 
and capriciously fails to relate selected restoration alterna-
tives to the "services" provided by the resource; 3 (4) the rule 
allows recovery for purely speculative losses regarding the 
affected resource's ability to assimilate future releases; (5) 
the rule authorizes recovery of private losses related to 
commercial fishing and hunting; (6) the rule's databases and 
computer submodels are not the "best available procedures" 
for determining NRD and invalidly rely on outdated studies 
and information or on suspect methodologies or both; (7) the 
rule permits a trustee to use Type A and Type B procedures 
________
     3 Natural resource "services" consist of "the physical and biologi-
cal functions performed by the resource including the human uses 
of those functions.  These services are the result of the physical, 
chemical, or biological quality of the resource."  43 C.F.R. 
s 11.14(nn) (1996).



in combination to assess NRD from a single release; 4  and (8) 
the rule provides for calculation of NRD resulting from 
releases or discharges of oil, notwithstanding the enactment 
of the Oil Pollution Act of 1990, 33 U.S.C. ss 2701 et seq., 
which authorizes the National Oceanic and Atmospheric Ad-
ministration to regulate oil releases or discharges.

     DOI contends that NAM's first and fifth claims are untime-
ly, the third claim was not raised below, one of the arguments 
included in NAM's seventh claim is not ripe for review and 
the eighth claim should be dismissed for lack of jurisdiction.  
Additionally, DOI responds on the merits, arguing that its 
interpretation of the relevant CERCLA provisions is entitled 
to deference under Chevron USA, Inc. v. Natural Resources 
Defense Council, Inc., 467 U.S. 837 (1984).  In addition, DOI 
contends that its damage submodels are otherwise reason-
able, scientifically valid and adequately supported by credible 
studies.

     We conclude that NAM failed to raise the third claim below 
and that it lacks standing to bring the eighth claim.  Regard-
ing the remaining claims, we conclude that DOI's interpreta-
tion of relevant CERCLA provisions is entitled to deference 
under step two of the familiar Chevron analysis and that its 
damage submodels suffice.  Accordingly, we deny NAM's 
request to set aside DOI's 1996 Type A rule, as amended.5

                                I. BACKGROUND


     Section 301(c) of CERCLA recites:
________
     4 The "Type A" and "Type B" titles come from the clauses of 
subsection 301(c)(2):  clause "A" requires DOI to develop "standard 
procedures for simplified assessments" and clause "B" requires DOI 
to develop "alternative protocols for conducting assessments in 
individual cases."  42 U.S.C. s 9651(c)(2).

     5 DOI informed the court that it promulgated certain technical 
corrections to the May 1996 rule on November 10, 1997.  See 
Natural Resource Damage Assessments--Type A Procedures, 62 
Fed. Reg. 60,457 (1997) (hereinafter Revisions to 1996 Type A rule).  
As discussed infra notes 16 and 23, the corrections moot two of 
NAM's challenges to the Type A procedures.



          (1) The President, acting through Federal officials 
     designated by the National Contingency Plan published 
     under section 9605 of this title, shall study and, not later 
     than two years after December 11, 1980 shall promulgate 
     regulations for the assessment of damages for injury to, 
     destruction of, or loss of natural resources resulting from 
     a release of oil or a hazardous substance for the purposes 
     of this chapter and section 1321(f)(4) and (5) of Title 33.  
     Notwithstanding the failure of the President to promul-
     gate the regulations required under this subsection on 
     the required date, the President shall promulgate such 
     regulations not later than 6 months after October 17, 
     1986.

          (2) Such regulations shall specify (A) standard proce-
     dures for simplified assessments requiring minimal field 
     observation, including establishing measures of damages 
     based on units of discharge or release or units of affected 
     area, and (B) alternative protocols for conducting assess-
     ments in individual cases to determine the type and 
     extent of short- and long-term injury, destruction, or 
     loss.  Such regulations shall identify the best available 
     procedures to determine such damages, including both 
     direct and indirect injury, destruction, or loss and shall 
     take into consideration factors including, but not limited 
     to, replacement value, use value, and ability of the eco-
     system or resource to recover.

          (3) Such regulations shall be reviewed and revised as 
     appropriate every two years.

42 U.S.C. s 9651(c).  Trustees must retain sums recovered 
for NRD "without further appropriation, for use only to 
restore, replace, or acquire the equivalent of [the damaged] 
resources."  42 U.S.C. s 9607(f)(1).  Further, "[t]he measure 
of damages in any action ... [is] not ... limited by the sums 
which can be used to restore or replace" the affected re-
sources, although CERCLA proscribes "double recovery ... 
for natural resource damages, including the costs of damage 
assessment or restoration, rehabilitation, or acquisition for 


the same release and natural resource."  42 U.S.C. 
s 9607(f)(1).

     As the final sentence of subsection 301(c)(1) foresaw, devel-
opment of Type A and Type B procedures has not been 
accomplished as expeditiously as the Congress directed.  To-
day, more than 17 years after section 301(c) of CERCLA was 
enacted, DOI has developed "simplified assessment[ ]" (i.e., 
Type A) procedures for only two aquatic environments:  (1) 
the Great Lakes environments and (2) coastal and marine 
environments.  The latter were the first Type A procedures 
developed;  they were promulgated in 1987, see Natural Re-
source Damage Assessments, 52 Fed. Reg. 9042 (1987) (codi-
fied at 43 C.F.R. pt. 11 (1988)) (hereinafter 1987 Type A rule), 
and subsequently reviewed by this court, see Colorado v. 
DOI, 880 F.2d 481 (D.C. Cir. 1989).  In Colorado we upheld 
the 1987 Type A rule in part and vacated it in part, relying on 
our companion decision reviewing a challenge to DOI's Type 
B rule.  See Ohio v. DOI, 880 F.2d 432 (D.C. Cir. 1989) 
[hereinafter Ohio II]. After Colorado--in which we stated 
that "[w]e fully expect DOI to act as expeditiously as possi-
ble," 880 F.2d at 491--DOI spent almost seven more years 
revising the Type A procedures and adding to them submo-
dels for assessing NRD in Great Lakes environments.  See 
1996 Type A rule, 61 Fed. Reg. at 20,560.

     In light of the delay, it is indeed fortunate that a trustee 
has authority under CERCLA to settle claims for NRD 
without recourse to either Type A or Type B procedures.  
See 42 U.S.C. s 9622.  Even if claims are not settled, a 
trustee is under no obligation to use Type A or Type B 
procedures to calculate damages--although the trustee must 
use the procedures if it wishes to use the rebuttable presump-
tion provided for in subsection 107(f))(2)(C) of CERCLA, 42 
U.S.C. s 9607(f)(2)(C).  See 43 C.F.R. s 11.10 (1996).

     If a trustee decides that a formal assessment is needed to 
effect recovery of NRD, the trustee must complete four 
administrative steps:  (1) Preassessment, (2) Assessment 
Plan, (3) Assessment and (4) Post Assessment.  1996 Type A 
rule, 61 Fed. Reg. at 20,562.  The first step, Preassessment, 


consists of "rapid review of readily available information that 
focuses on resources for which the Federal or State agency or 
Indian tribe may assert trusteeship under section 107(f) or 
section 126(d) of CERCLA."  43 C.F.R. s 11.23(b) (1996).  
The purpose of the Preassessment is to "ensure that there is 
a reasonable probability of making a successful claim before 
monies and efforts are expended in carrying out an assess-
ment."  Id.

     The second step, the Assessment Plan, is undertaken "to 
ensure that the assessment is performed in a planned and 
systematic manner and that methodologies selected ... for a 
type A assessment or ... for a type B assessment ... can be 
conducted at a reasonable cost."  43 C.F.R. s 11.30(b).  "The 
Assessment Plan must identify and document the use of all of 
the type A and/or type B procedures that will be performed 
... [and] be of sufficient detail to serve as a means of 
evaluating whether the approach used for assessing the dam-
age is likely to be cost-effective and meets the definition of 
reasonable cost, as those terms are used" in the applicable 
regulations.  Id. s 11.31(a)(1)-(2).

     A trustee can use Type A procedures if six environmental 
conditions are met:

          (a) The released substance entered an area covered by 
     the [coastal and marine or Great Lakes procedures] ...

          (b) The [type A procedures] cover the released sub-
     stance[;] ...

          (c) The released substance entered the water at or 
     near the surface[;] ...

          (d) At the time of the release, winds did not vary 
     spatially over the area affected by the release in a way 
     that would significantly affect the level or extent of 
     injuries;

          (e) The authorized official is not aware of any reliable 
     evidence that, for species that are likely to represent a 
     significant portion of the claim, the species biomass is 
     significantly lower than the species biomass assigned by 
     the [relevant computer submodels][; and] ...



          (f) Subsurface currents either:  are not expected to 
     significantly affect the level or extent of injuries;  or are 
     reasonably uniform with depth over the water column in 
     the area affected by the release.

43 C.F.R. s 11.34 (1996).  If a release is within these environ-
mental parameters, a preliminary assessment of damages is 
performed according to Type A procedures and included in 
the draft Assessment Plan made available for public review 
and comment.  Id. s 11.43.  If the preliminary assessment 
indicates that damages will exceed $100,000, a trustee must 
either "(1) limit the portion of [the trustee's] claim calculated 
with the type A procedure to $100,000;  or (2) compute all 
damages using type B procedures."  Id. s 11.42(b).  Never-
theless "[t]he $100,000 limit applies only to damages calculat-
ed by a type A procedure and does not limit damages 
calculated through supplemental type B studies."  1996 Type 
A rule, 61 Fed. Reg. at 20,563.

     In deciding whether to use Type A or Type B procedures 
(or some combination of the two), the trustee must "weigh[ ] 
the difficulty of collecting site-specific data against the suita-
bility of the averaged data and simplifying assumptions in the 
type A procedure for the release being assessed."  43 C.F.R. 
s 11.35(a) (1996).  The trustee may elect to use Type B 
procedures if "they can be performed at a reasonable cost and 
if the increase in accuracy outweighs the increase in assess-
ment costs."  Id.  Even if a trustee decides to use Type A 
procedures, a PRP may nonetheless insist on Type B proce-
dures.  See id. s 11.35(b); 1996 Type A rule, 61 Fed. Reg. at 
20,562.

     A trustee may use both Type A and Type B procedures to 
calculate NRD for the same release if the following criteria 
are met:

          (1) The type B procedures are cost-effective and can 
     be performed at a reasonable cost;

          (2) There is no double recovery; and

          (3) The type B procedures are used only to determine 
     damages for injuries or compensable values that do not 


     fall into the categories addressed by the type A proce-
     dure.

43 C.F.R. s 11.36(a) (1996).  If a trustee decides to use both 
kinds of procedures, it "must document in the Assessment 
Plan how [it] intend[s] to prevent double recovery."  1996 
Type A rule, 61 Fed. Reg. at 20,563.

     The third step of the process, "Assessment," is subdivided 
into three phases:

     Injury Determination; Quantification; and Damage De-
     termination.  In Injury Determination, trustees deter-
     mine whether any natural resources have been injured.  
     If trustees determine that resources have been injured, 
     they proceed to Quantification, in which they quantify the 
     resulting change in baseline conditions.  "Baseline" con-
     ditions are the conditions that would have existed had the 
     release not occurred.  Finally, in Damage Determination, 
     trustees calculate the monetary compensation to be 
     sought as damages for the natural resource injuries.  
     Damages include two components:  (1) the cost of restor-
     ing, rehabilitating, replacing, and/or acquiring the equiva-
     lent of the injured natural resources; and (2) the eco-
     nomic value lost by the public pending recovery of the 
     resources (compensable value).

          When trustees use type B procedures, they perform 
     Injury Determination, Quantification, and Damage De-
     termination through laboratory and field studies....

          When trustees use a type A procedure, they perform 
     Injury Determination, Quantification, and Damage De-
     termination through a computer model....

          Trustees must supply a number of data inputs to 
     operate the [Type A submodels].  The rule also requires 
     trustees to modify certain data contained in the models if 
     they have more reliable information....  After trustees 
     supply the data inputs and modifications, the models 
     themselves perform the remaining calculations necessary 
     to establish if there has been an injury, quantify the 
     extent of injury, select appropriate restoration actions, 


     and value economic losses.  With the availability of these 
     computer models, trustees will now be able to pursue 
     compensation for cases in which the cost of detailed type 
     B studies is prohibitive.

1996 Type A rule, 61 Fed. Reg. at 20,562-63.  While the Type 
A computer submodels take into account a number of "site 
specific factors," including "physical variations among geo-
graphic areas, differences in the toxicity and physical charac-
teristics of hazardous substances, seasonal and temperature 
effects, and differences in the biological productivity of the 
spill site," they do not require on-site testing, nor do they 
require empirical testing to establish a causal link between 
the release and any observable injury.  Id. at 20,563.

     Four computer programs comprise the Type A submodels 
and perform the damage calculations at the Assessment 
stage:  (1) the Physical Fates Submodel, (2) the Biological 
Effects Submodel, (3) the Restoration Submodel and (4) the 
Compensable Value Submodel.  1996 Type A rule, 61 Fed. 
Reg. at 20,565-67.  "The physical fates submodel estimates 
the distribution of the released substance on the water sur-
face, along shorelines, in the water column, and in sediments 
over time."  Id. at 20,565.  "The biological effects submodel 
determines whether certain types of natural resource injuries 
have resulted from the release and, if so, quantifies those 
injuries."  Id.  "The restoration submodel estimates the cost, 
if any, of restoring the injured resources."  Id.  Finally, 
"[c]ompensable value, as computed by the compensable value 
submodel, is the sum of certain economic use values lost to 
the public pending reestablishment of baseline conditions 
through either natural recovery or active restoration, as 
determined by the restoration submodel."  Id. at 20,566.

     The fourth and final step of the process is the Post-
Assessment phase, at which time the trustee prepares a 
"Report of Assessment that consists of the Preassessment 
Screen Determination, the Assessment Plan, and the informa-
tion" used by the Type A submodels to calculate damages.  
43 C.F.R. s 11.90(a) (1996).  A copy of the report is then 
attached to the demand letter the trustee sends the PRP.  Id. 


s 11.91.  Finally, the trustee prepares a Restoration Plan, as 
required by section 111(i) of CERCLA, 42 U.S.C. s 9611, 
which details "how the monies [recovered] will be used to 
address natural resources, specifically, what restoration, reha-
bilitation, replacement, or acquisition of the equivalent re-
sources will occur."  Id. s 11.93(a).

                                II. DISCUSSION


     The yardstick by which we assess the petitioner's APA and 
Chevron challenges to the 1996 Type A rule is the one we 
used in Colorado:

          We review DOI's type A rules, promulgated after 
     informal notice and comment rulemaking procedures un-
     der the Administrative Procedure Act, see 5 U.S.C. 
     s 553(c), under the familiar "arbitrary, capricious, an 
     abuse of discretion, or otherwise not in accordance with 
     law" standard, see id. s 706(2)(A).  Under this standard, 
     we are mindful a reviewing court is "not to substitute its 
     judgment for that of the agency."  Citizens to Preserve 
     Overton Park v. Volpe, 401 U.S. 402, 416, 91 S.Ct. 814, 
     823, 28 L.Ed.2d 136 (1971).

          Moreover, it is well-established that when presented 
     with "a pure question of statutory construction," a re-
     viewing court's "first job is to try to determine congres-
     sional intent using 'traditional tools of statutory construc-
     tion,' " NLRB v. United Food & Commercial Workers, 
     Local 23, 484 U.S. 112, 108 S.Ct. 413, 421, 98 L.Ed.2d 429 
     (1987) (quoting INS v. Cardozo-Fonseca, 480 U.S. 421, 
     107 S.Ct. 1207, 1221, 94 L.Ed.2d 434 (1987)), for if 
     "Congress has directly spoken to the precise question at 
     issue," then "the court, as well as the agency, must give 
     effect to the unambiguously expressed intent of Con-
     gress," Chevron U.S.A., Inc. v. NRDC, 467 U.S. 837, 842-
     43, 104 S.Ct. 2778, 2781-82, 81 L.Ed.2d 694 (1984).  If, 
     however, "the statute is silent or ambiguous with respect 
     to the specific issue," id. at 843, 104 S.Ct. at 2782, then 
     the question becomes whether the agency charged with 
     implementing the statute--DOI in this case--has made a 


     "reasonable" interpretation, id. at 845, 104 S.Ct. at 2783, 
     i.e., one that is "rational and consistent with the statute."  
     United Food & Commercial Workers, 108 S.Ct. at 421.

880 F.2d at 486.

     Thus, in reviewing an APA challenge to an agency's techni-
cal judgments incorporated in a submodel, "the agency's 
choice of model and its application must be respected when 
the record discloses that the agency examined the relevant 
data and articulated a reasoned basis for its decision."  Ohio 
II, 880 F.2d at 479.  Similarly, when reviewing an agency's 
technical judgments under step two of Chevron, we ask 
whether the agency's choices are "reasonable and consistent 
with congressional intent, and therefore worthy of deference."  
Id. at 477; accord Kennecott Utah Copper Corp. v. DOI, 88 
F.3d 1191, 1225 (D.C. Cir. 1996) (noting need to "defer to the 
agency's decision about how to strike th[e] balance" between 
conflicting statutory and policy goals "unless [the decision] is 
unreasonable").  Moreover, in applying both of these stan-
dards to the scientific judgment of an agency, we do not 
"review scientific judgments of the agency ... as the chemist, 
biologist, or statistician that we are neither qualified by 
training nor experience to be, but as a reviewing court 
exercising our narrowly defined duty of holding agencies to 
certain minimal standards of rationality," Troy Corp. v. 
Browner, 120 F.3d 277, 283 (D.C. Cir. 1997) (internal quota-
tion marks omitted), or, in the context of Chevron step two, 
assuring at a minimum the reasonableness of the judgment in 
light of the requirements imposed (or discretion granted) by 
the authorizing statute.

                   A. Verification of Injury and Causation


     NAM first argues that DOI's Type A rule, which relies on 
computer submodels to calculate the types and amounts of 
damages that are rebuttably presumed to result from a 
particular release, violates subsections 107(a)(C) and 301(c)(1) 
of CERCLA, which limit recovery to damages "resulting from 
a release."  42 U.S.C. ss 9607(a)(C), 9651(c)(1).  Since DOI's 
computer submodels require only limited, site-specific data to 


calculate damages, NAM contends that they improperly re-
lieve the trustee of its burden to demonstrate that a particu-
lar release in fact caused injury to a specific natural resource.  
Further, NAM reasons that even if such submodels could in 
theory be used to calculate NRD, the submodels DOI has 
developed are too crude to reliably predict injuries to natural 
resources that are likely to "result from" releases and are 
therefore inconsistent with the command of subsection 
301(c)(2) to "identify the best available procedures to deter-
mine ... damages."  See Ohio II, 880 F.2d at 462 ("Congress 
directed DOI to select ... 'best available' methodologies for 
determining damages, 42 U.S.C. s 9651(c)(2), and a proce-
dure that permitted unduly speculative assessments would 
not fulfill this intent.").  We reject both arguments on their 
merits.

                          (1) Timeliness of challenge


     DOI first responds that NAM's challenge is time-barred 
under section 113(a) of CERCLA, 42 U.S.C. s 9613(a), which 
requires that a petition for review of a final regulation be 
brought "within 90 days from the date of [its] promulgation."  
DOI reasons that since its 1987 Type A rule relied on the 
same kind of predictive computer submodels to establish 
causation and injury, NAM's challenge now is untimely be-
cause it should have been brought, if at all, in 1987.  DOI is 
mistaken.

     While an agency need not subject settled policy or estab-
lished statutory interpretation to renewed legal challenge 
whenever it revises a regulation, "the period for seeking 
judicial review may be made to run anew when the agency in 
question by some new promulgation creates the opportunity 
for renewed comment and objection."  Ohio v. EPA, 838 F.2d 
1325, 1329 (D.C. Cir. 1988) [hereinafter Ohio I]. Thus, in Ohio 
I we held that, although the petitioner had an opportunity to 
comment on the relevant provision in the original regulation, 
it was not barred from challenging the provision in the 
revised regulation because the agency had republished the 
provision, explained it anew and responded to at least one 


comment directed to it.  Id. at 1328-29; see also Kennecott, 
88 F.3d at 1213 ("[J]udicial review of longstanding regulation 
is not barred when an agency reopens an issue covered in, or 
changes its interpretation of, that regulation; e.g., if an 
agency in the course of a rulemaking proceeding solicits 
comments on a pre-existing regulation or otherwise indicates 
its willingness to reconsider such a regulation by inviting and 
responding to comments, then a new review period is trig-
gered.").  However, "[t]he 'reopening rule' of [Ohio I] is not a 
license for bootstrap procedures by which petitioners can 
comment on matters other than those actually at issue, goad 
an agency into a reply, and then sue on the grounds that the 
agency had re-opened the issue."  American Iron & Steel 
Inst. v. EPA, 886 F.2d 390, 398 (D.C. Cir. 1989), cert. denied, 
497 U.S. 1003 (1990).  Thus, "when the agency merely re-
sponds to an unsolicited comment by reaffirming its prior 
position, that response does not create a new opportunity for 
review."  Kennecott, 88 F.3d at 1213.

     Moreover, "the appropriate way to challenge a longstand-
ing regulation on the ground that it is 'violative of statute' is 
ordinarily 'by filing a petition for amendment or rescission of 
the agency's regulations, and challenging the denial of that 
petition.' "  Id. at 1214 (quoting Public Citizen v. Nuclear 
Regulatory Comm'n, 901 F.2d 147, 152 (D.C. Cir.), cert. 
denied, 498 U.S. 992 (1990)).  But "where an agency reit-
erates a rule or policy in such a way as to render the rule or 
policy subject to renewed challenge on any substantive 
grounds, a coordinate challenge that such a rule or policy is 
contrary to law" need not proceed by amendment or rescis-
sion petition.  Public Citizen, 901 F.2d at 152-53.  In such 
circumstances, to require that an administrative petition pre-
cede the "coordinate challenge" to the lawfulness of the 
agency's provision "would be a waste of time and resources."  
Kennecott, 88 F.3d at 1214.

     An agency may be deemed to have "constructively re-
opened" a previously unchallenged decision if its original 
rulemaking did not give adequate notice or incentive to 


contest the agency's decision.  For example, as a result of the 
partial invalidation of the 1986 Type B rule in the Ohio II 
litigation,

     our invalidation of that rule might have changed the 
     stakes of a court challenge.  In this situation, we would 
     likely hold that Interior's adherence to its resolution of 
     certain issues that arose in the course of the 1986 
     proceeding was, even if not expressly reopened in its 
     1994 rulemaking, constructively reopened by the change 
     in regulatory context.  For us to foreclose review of the 
     agency's decision to adhere to the status quo ante under 
     changed circumstances, on the grounds that the agency 
     had not evidenced a willingness to reconsider the issue, 
     would be to deny the significance of our own earlier 
     ruling.

Kennecott, 88 F.3d at 1214.  Thus, "[b]efore any litigant 
reasonably can be expected to present a petition for review of 
an agency rule, he first must be put on fair notice that the 
rule in question is applicable to him."  Recreation Vehicle 
Indus. Ass'n v. EPA, 653 F.2d 562, 568 (D.C. Cir. 1981).  
Accordingly, in Recreation Vehicle the court held that be-
cause it was unclear that EPA's final rule on noise emission 
levels for medium and heavy trucks applied to motor homes, 
"[t]he agency cannot now take advantage of the obscurity of 
its intentions in order to defeat [the petitioner's] rights 
statutorily conferred."  Id.

     Here, DOI's substantial revisions to the Type A procedures 
significantly altered the "regulatory context."  In particular, 
the circumstances in which a trustee may elect to use Type A 
procedures to calculate damages have been significantly modi-
fied by the 1996 revisions.  For example, a trustee may now 
supplement Type A procedures with selected Type B proto-
cols, it may use Type A procedures in circumstances where 
species mortality may not be the anticipated principal adverse 
effect, it may use Type A procedures even if the release does 
not result in closing a fishing, beach or hunting area and it 


may now utilize Type A procedures for releases in both Great 
Lakes and coastal and marine environments.  Compare 43 
C.F.R. s 11.33 (1987) with 43 C.F.R. ss 11.34, 11.35, 11.36, 
11.42(b) (1996).6  Thus, although DOI may not have intended 
to reopen the issue of the predictive aspect of its computer 
submodels' calculations of injury and causation, see 1996 Type 
A rule, 61 Fed. Reg. at 20,582, the different regulatory 
context wrought by the 1996 rule "significantly alter[ed] the 
stakes of judicial review," Kennecott, 88 F.3d at 1227, and 
thereby constructively reopened to challenge the predictive 
nature of the computer submodels.
________
     6 Kennecott also holds that there is no "constructive reopening" if 
"parties had adequate notice of a forthcoming change that might 
alter their incentive to seek judicial review."  88 F.3d at 1214.  
There, because potential litigants were on notice during the pen-
dency of legal challenges to DOI's Type B rule (i.e., Ohio II) "that 
restoration cost rather than market value could become the pre-
dominant basis for damage assessments," we held that litigants 
"had an ample incentive at that time [i.e., before 1989 decision in 
Ohio II] to protest any provision [of the 1986 Type B rule] that 
might inflate restoration costs."  Id. at 1215.

     This case is distinguishable.  Although DOI issued an advance 
notice of proposed rulemaking (ANPR) for the Great Lakes proce-
dures in June 1988 (see Natural Resource Damage Assessments, 53 
Fed. Reg. 20,143, 20,143-46 (1988)) while our review of the 1987 
Type A rule was still pending, we do not believe that the ANPR was 
sufficient to put NAM or other interested parties on notice that the 
yet-to-be-developed Type A procedures for the Great Lakes would 
permit calculation of NRD for a release without on-site verification 
of injury and causation.  In contrast to the Type B provisions at 
issue in Kennecott, the Great Lakes submodels were not a part of 
the Type A rule that DOI initially promulgated in 1987.  Thus, 
unlike the Ohio II challenge, the Colorado litigation did not alert 
NAM and other potentially interested parties that a vestigial provi-
sion of the 1987 rule might have added significance as a result of 
that litigation.  Therefore, Recreational Vehicles rather than Ken-
necott supplies the rule of decision:  "Before any litigant reasonably 
can be expected to present a petition for review, he first must be 
put on fair notice that the rule in question is applicable to him."  
653 F.2d at 568.



                            (2) Merits of challenge


     DOI fares better responding to the merits of NAM's chal-
lenge--that CERCLA sections 107(a)(C) and 301(c)(1) autho-
rize a trustee to recover damages only for those injuries 
"resulting from ... a release"; DOI's Type A procedures 
permit a trustee to recover damages without any on-site, 
empirical verification that injury has in fact "result[ed] from" 
a particular release; therefore, DOI's predictive damage cal-
culators are violative of CERCLA.

     Contrary to NAM's contentions, we find nothing in the 
relevant provisions of CERCLA that requires greater proof 
of causation and injury than is provided by DOI's predictive 
computer submodels.  Regarding causation, this court has 
repeatedly held that CERCLA is ambiguous on the precise 
question of what standard of proof is required to demonstrate 
that natural resource injuries were caused by, or "result[ ] 
from," a particular release.  See Ohio II, 880 F.2d at 472 
("[W]hile we agree with petitioners that Congress expressed 
dissatisfaction with the common law as a norm in several 
areas of damage assessment, we conclude that CERCLA is at 
best ambiguous on the question of whether the causation-of-
injury standard under s 107(a)(C) must be less demanding 
than that of the common law."); Kennecott, 88 F.3d at 1224 
("CERCLA left it to Interior to define the measure of dam-
ages in natural resources damage assessment cases....  
While the statutory language requires some causal connection 
between the element of damages and the injury--the dam-
ages must be 'for' an injury 'resulting from a release of oil or 
a hazardous substance'--Congress has not specified precisely 
what that causal relationship should be.") (citation omitted).

     Similarly, we find nothing in the "resulting from" language 
of subsections 107(a)(C) and 301(c)(1), or other provisions of 
CERCLA, to indicate that the Congress unambiguously in-
tended a particular kind or quantity of causation and injury 
proof as a prerequisite to recovery of NRD.  While we have 
noted that the "best available procedures" language of sub-


section 301(c)(2) indicates that it would be inconsistent with 
CERCLA to permit "unduly speculative assessments," Ohio 
II, 880 F.2d at 462, we have never held that simply because 
assessments procedures are in some measure "speculative" or 
"predictive" they are contrary to CERCLA's "best available 
procedures" admonition.  Rather, predictive submodels that 
represent rational scientific judgments about the probability 
that a particular release will cause a specific type and amount 
of injury are consistent with the Congress's intent to develop 
a "standardized system for assessing such damage which is 
efficient as to both time and cost."  S. Rep. No. 96-848, at 85 
(1980); 7  cf. Ohio II, 880 F.2d at 455 ("[S]upport for the 
proposition that Congress adopted common-law damage stan-
dards wholesale into CERCLA is slim to nonexistent.").

     Moreover, contrary to NAM's suggestions, the fact that the 
Congress may have generally viewed recovery of NRD as a 
"compensatory remedy"--see 1996 Type A rule, 61 Fed. Reg. 
at 20,582; 42 U.S.C. s 9607(f)(1)--does not mean that the 
Congress intended to require adducement of a particular 
quality and quantity of proof of injury, loss or destruction 
before allowing recovery.  Rather, DOI developed the Type A 
procedures so that the public would be compensated for the 
NRD resulting from minor spills;  the kind of spill ill suited 
for the expensive and resource-intensive Type B procedures.  
Cf. 1996 Type A final rule, 61 Fed. Reg. at 60,572 ("Because 
of the cost involved in performing site-specific type B studies, 
trustees have rarely pursued damage claims for minor releas-
es.").

     Accordingly, we proceed to the second step of the Chevron 
analysis, where "we ask whether [DOI] has adopted a reason-
able interpretation of the statute--that is whether the agency 
considered the matter in a detailed and reasoned fashion and 
whether the interpretation is arguably consistent with the 
underlying statutory scheme in a substantive sense."  Kenne-
________
     7 As we observed in Colorado, "[b]ecause the House concurred in 
the Senate bill [that became CERCLA] without amendment, see 126 
Cong. Rec. 31,950-82 (1980), th[is] Senate report is powerful evi-
dence of congressional intent."  880 F.2d at 487.



cott, 88 F.3d at 1206 (internal quotations omitted); accord 
Ohio II, 880 F.2d at 441 ("If ... the statute is ambiguous or 
silent on a particular issue, this court must assume that 
Congress implicitly delegated to the agency the power to 
make policy choices that represent a reasonable accommoda-
tion of conflicting policies that are committed to the agency's 
care by the statute....  In that event, the court must defer 
to the agency's interpretation of the statute so long as it is 
reasonable and consistent with the statutory purpose.").8  Ac-
cording DOI's interpretation the deference it is due under 
Chevron step two, we conclude that DOI's reliance on pre-
dictive computer submodels to establish causation and injury 
is both reasonable and consistent with the commands of 
CERCLA.

     Subsection 301(c)(2), 42 U.S.C. s 9651(c)(2), the only 
CERCLA provision that speaks directly to the form and 
content of Type A procedures, states that the "regulations 
shall specify ... standard procedures for simplified assess-
ments requiring minimal field observation, including estab-
lishing measures of damages based on units of discharge or 
release or units of affected area ...." (emphasis added).  
________
     8 Nor can our decision in General Electric Co. v. United States 
Department of Commerce, 128 F.3d 767 (D.C. Cir. 1997), be read to 
require a different conclusion here.  In General Electric we were 
asked to pass on the National Oceanic and Atmospheric Administra-
tion's (NOAA's) regulation regarding NRD claims for releases of oil 
or petroleum products covered by the Oil Pollution Act of 1990 
(OPA).  While we upheld NOAA's determination that its computer 
submodels should be " 'reliable and valid for the particular inci-
dent,' " 128 F.3d at 772 (quoting 15 C.F.R. s 990.27(a)(3)), we did 
not conclude that such validation procedures were a necessary 
feature of the regulations authorized by OPA, nor did we suggest 
that the related but independent regulatory scheme established by 
CERCLA contained any such requirement.  Further, although we 
briefly noted that NOAA's regulations provided a sufficient stan-
dard by which to assess the agency's exercise of discretion in 
calculating damages from oil releases, 128 F.3d at 778-79, we did 
not suggest that such a provision was essential for a court to assess 
the reasonableness and accuracy of damage calculations.



DOI's Type A submodels appear consistent with the charge to 
develop standardized and simplified assessment procedures 
that require minimal field observation and that estimate 
damages according to the type, amount (i.e., "units of dis-
charge or release"), location (i.e., "units of affected area") and 
other objective characteristics of a release.  As DOI itself 
observed, "[i]nherent in the concept of developing unit values 
from existing studies is the notion of making assumptions in 
the absence of empirical data and applying average values 
across a range of nonidentical items."  1996 Type A rule, 61 
Fed. Reg. at 20,571.  The Senate committee that favorably 
reported on the Senate bill that became CERCLA also envi-
sioned streamlined Type A procedures that would "require as 
little fieldwork as possible, and rely on a combination of 
habitat values, tables of values for individual species, and 
previously conducted surveys and laboratory studies, related 
to units of discharge or units of affected area."  S. Rep. No. 
96-848, at 86; cf. Colorado, 880 F.2d at 489-90 (declining to 
"second-guess DOI's technical determination" to use comput-
er submodels, notwithstanding legislative history indicated 
use of tables would be consistent with congressional intent).  
Thus, DOI's interpretation of subsection 301(c)(2)(A) to per-
mit the use of predictive computer submodels to determine 
causation and injury is plainly reasonable.  To the extent that 
the "resulting from" language of subsections 107(a)(C) and 
301(c)(1) suggests a need for more definite proof of injury and 
causation than is suggested by subsection 301(c)(2)(A), we 
find that DOI's decision to address the potential inconsistency 
in legislative purpose by development of predictive computer 
submodels is "a reasonable accommodation of conflicting poli-
cies that are committed to the agency's care by the statute."  
Ohio II, 880 F.2d at 441.9
________
     9 DOI explained its resolution of the potentially conflicting com-
mands of subsections 107(a)(C), 301(c)(1) and 301(c)(2)(A) as follows:

     There is a tension between the statutory provision requiring 
     trustees to demonstrate that injury "resulted from" a release 
     and the provision requiring the development of simplified as-
     sessment procedures that involve "minimal field observation."  
     As noted in the cases cited by commenters, the requirement 



     Nor is NAM's assertion that it is unreasonable for DOI to 
require site-specific verification of damage, i.e., a "reality 
check," for its Type B procedures but not for its Type A 
procedures persuasive.  The assertion ignores the significant 
differences between Type A and Type B procedures that both 
the text and the history of CERCLA affirm.  In contrast to 
the "standard[ized]" procedures called for in subsection 
301(c)(2)(A), the Type B procedures are "for conducting as-
sessments in individual cases to determine the type and 
extent of short- and long-term injury, destruction, or loss."  
42 U.S.C. s 9651(c)(2)(B) (emphasis added).  The legislative 
history of subsection 301(c)(2) indicates that the Type A 
procedures are intended "to effectively deal with damage 
assessment in most 'minor' releases of hazardous material," S. 
Rep. No. 96-848, at 86 (1980), whereas the Type B proce-
________
     that trustees demonstrate that injury resulted from the release 
     indicates that Congress intended that natural resource damage 
     liability be compensatory.  PRPs are to be held liable not just 
     because they are responsible for a release but because they are 
     responsible for a release that caused an adverse effect.  On the 
     other hand, by requiring the development of type A proce-
     dures, Congress recognized that assessment work can be ex-
     pensive and time consuming.  In the case of minor releases, it 
     is often not cost-effective or feasible to conduct more than 
     minimal field observations.  The Department has struggled to 
     resolve the tension between these two statutory requirements 
     by developing Type A procedures that rely on computer models 
     to predict actual site-specific effects to the maximum extent 
     practicable but do not require on-site verification of the models' 
     injury predictions.

* * *

          In fact, as discussed above, the legislative history of 
     CERCLA suggests that the Department would have been 
     justified in developing a look-up table or compensation formula 
     as a type A procedure.  Instead, the type A models use both 
     site-specific information provided by the trustees and biological 
     and environmental information about the spill site contained in 
     the database to approximate more precisely the actual effects 
     of the release.

1996 Type A rule, 61 Fed. Reg. at 20,581-82.



dures are needed to address "large or unusually damaging 
releases and would be used to guide the site-specific damage 
assessment," id.  We therefore agree with DOI that the text 
and the history of subsection 301(c)(2) fully support its deci-
sion to insist on a "reality check" only when the more 
extensive and individually-tailored Type B procedures are 
used.

     In addition, the restrictive interpretation of subsections 
107(a)(C) and 301(c)(1) that NAM urges here ignores the 
purpose and effect of subsection 301(c)(2), which plainly in-
tends a distinction between the two types of procedures.  As 
we have repeatedly counseled, such an interpretation, which 
essentially deprives one provision of its meaning and effect so 
that another provision can be read as broadly as its language 
will permit, is inconsistent with the Congress's intent as well 
as our Chevron analysis.  Cf. Halverson v. Slater, 129 F.3d 
180, 185 (D.C. Cir. 1997) (rejecting agency interpretation of 
its general delegation provision because interpretation would 
render more specific and directly applicable delegation provi-
sion meaningless);  Watt v. Alaska, 451 U.S. 259, 267 (1981) 
("We must read the statutes to give effect to each if we can 
do so while preserving their sense and purpose.").  Thus, 
NAM's suggested resolution of the potential conflict in pur-
pose posed by subsections 107(a)(C), 301(c)(1) and 301(c)(2), 
would once again improperly call for us to give the "resulting 
from" language of subsections 107(a)(C) and 301(c)(1) a more 
restrictive meaning than the Congress intended.  Cf. Ohio II, 
880 F.2d at 446 n.14 ("Industry Intervenors advance a related 
argument, to the effect that Congress' choice of the word 
'damages' in s 107(a)(C) should be read to incorporate the 
common-law meaning of the term.  In the first place, this 
argument loads a great deal of baggage onto an everyday 
word which has long since transcended its origins and is now 
defined in Webster's Dictionary as 'compensation in money 
imposed by law for loss or injury.'  ... Moreover, as our 
examination of CERCLA's legislative history indicates, ... 
Congress' dissatisfaction with the common law provided a 
central motivation for enacting CERCLA.") (internal citations 
omitted).  Accordingly, given the interrelated and cross-


referenced nature of CERCLA subsections 107(a)(C), 
107(f)(1), 301(c)(1) and 301(c)(2), we find that DOI's decision 
to require a "reality check" for Type B but not for Type A 
procedures reads the provisions in an appropriately harmoni-
ous way.  Cf. id. at 447 ("Indeed, the fact that subsection 
(f)(1) itself explicitly cross-references subsection (a)(C) as the 
source of liability indicates Congress' conscious design to read 
the two subsections as compatible and complementary:  liabili-
ty for 'damages is established in subsection (a)(C), while 
subsection (f)(1) orders DOI not to place a restoration-cost 
ceiling on the 'measure of damages.' ").

     NAM's other arguments, attacking the accuracy and relia-
bility of the submodels' predictions of injury and causation, 
are equally unpersuasive.  In American Iron & Steel Insti-
tute v. EPA, 115 F.3d 979 (D.C. Cir. 1997), we rejected a 
similar challenge, noting that

     [p]ossessing imperfect scientific information, [the agency] 
     had to decide whether to proceed on that basis or invest 
     the resources to conduct the perfect study.  It chose to 
     do the former.  This is the type of decision to which this 
     court will generally apply the deferential standard of 5 
     U.S.C. s 706(2)(A)....  Our deference, however, is not 
     without limits.  The agency's choice will be reversed as 
     arbitrary and capricious if there is "simply no rational 
     relationship" between the model chosen and the situation 
     to which it is applied.

115 F.3d at 1004; cf. Kennecott, 88 F.3d at 1225 ("Interior has 
balanced the need for an early, rough estimate against the 
danger of that estimate being too rough.  We must defer to 
the agency's decision about how to strike that balance unless 
it is unreasonable.").  Because DOI's Type A submodels are 
at least as scientifically rational and sophisticated as those we 
upheld in American Iron, we find no merit in NAM's conten-
tions that the submodels permit "unduly speculative assess-
ments" in contravention of the requirement that DOI "identi-


fy the best available procedures" for the calculation of NRD.10

     Finally, we note that nothing in the Type A regulations 
prevents a PRP that believes the submodels have erroneously 
found injury and causation from contesting the submodels' 
calculations--either with its own site-specific studies or with 
other evidence that calls into question the predictive calcula-
tions of the submodels.  The Type A rule also enables a PRP 
that suspects that a Type A assessment overstates the actual 
loss to insist on Type B procedures.  See 43 C.F.R. 
s 11.35(b).  Indeed, DOI revised its final rule

     to require trustees to perform a preliminary application 
     of the model and make the results available for public 
     comment before presenting a damage claim.  Therefore, 
     PRPs will have an opportunity to evaluate the injury 
     projections.  They can then decide whether they have 
     information that indicates that the projections are wrong 
     and that the user inputs need to be modified or that type 
     B procedures should be used.

1996 Type A rule, 61 Fed. Reg. at 20,582.

                 B. Replacement and Acquisition Alternatives


     NAM next argues that CERCLA subsections 107(f)(1) and 
301(c)(2) require that Type A procedures consider the costs of 
"replacement" or "acquisition of equivalent resources." 11  Be-
________
     10 The computer submodels, contrary to NAM's assertions, do not 
dispense with all "field observation" and thereby render superfluous 
the Congress's expectation that Type A procedures will require 
"minimal field observation."  Rather, for each release a number of 
site-specific variables must be collected and analyzed in order to 
compute damages.  While DOI "interprets 'minimal field observa-
tions' to be information that is readily or routinely collected follow-
ing a release," 1996 Type A rule, 61 Fed. Reg. at 20,582, the fact 
that it is "readily or routinely collected" does not make it any less 
site- or incident-specific.  Moreover, as discussed above, the Type A 
submodels contain certain safeguards so that they will not be 
applied when environmental or other assumptions do not reflect 
actual conditions as of the date of the release.  See supra Part I.

     11 In relevant part, subsection 107(f)(1) provides:



cause DOI's computer submodels do not expressly consider 
these costs in their NRD calculus, NAM contends that we 
must vacate the Type A rule.  We disagree.

     The subsection 107(f)(1) spending limitation--i.e., recover-
ies "shall be retained ... for use only to restore, replace, or 
acquire the equivalent" of affected resources--does not mean 
that a trustee must consider each of the alternative measures 
of damages in calculating NRD.  Cf. Kennecott, 88 F.3d at 
1230 ("Although ... spending priorities may, in turn, imply a 
hierarchy in the way trustees should assess damages in the 
first place, we do not find [in either the text of 107(f)(1) or in] 
the committee report a sufficiently clear statement of Con-
gressional intent necessary to resolve this issue under Chev-
ron step one.").  Indeed, the very next sentence of subsection 
107(f)(1) declares that "[t]he measure of damages ... shall 
not be limited by the sums which can be used to restore or 
replace" injured resources, which "carries in it an implicit 
assumption that restoration cost will serve as the basic mea-
sure of damages in many if not most CERCLA cases."  Ohio 
II, 880 F.2d at 446.

     More troublesome for DOI, however, is subsection 
301(c)(2), which requires that the Type A and B regulations 
"take into consideration factors including, but not limited to, 
replacement value, use value, and ability of the ecosystem or 
________
     Sums recovered by the United States Government as trustee 
     under this subsection shall be retained by the trustee, without 
     further appropriation, for use only to restore, replace, or 
     acquire the equivalent of such natural resources.  Sums recov-
     ered by a State as trustee under this subsection shall be 
     available for use only to restore, replace, or acquire the equiva-
     lent of such natural resources by the State.  The measure of 
     damages in any action under subparagraph (C) of subsection 
     (a) of this section shall not be limited by the sums which can be 
     used to restore or replace such resources.

42 U.S.C. s 9607(f)(1) (emphasis added).  The pertinent language of 
subsection 301(c)(2) recites that Type A and B regulations "shall 
take into consideration factors including, but not limited to, replace-
ment value, use value, and ability of the ecosystem or resource to 
recover."  42 U.S.C. s 9651(c)(2) (emphasis added).



resource to recover." 12  42 U.S.C. s 9651(c)(2) (emphasis 
added).  Absent from the list is "acquisition value," whose 
inclusion would strengthen the similarity to the spending 
limitation imposed by CERCLA subsection 107(f)(1).  None-
theless, we agree with DOI that the list may reasonably be 
read to require only that a number of different kinds of 
values for particular injury components be considered.  In-
deed, in Ohio II, we noted that subsection 301(c)(2) gave DOI 
discretion to fashion an appropriate measure of damages in a 
particular case although the discretion was circumscribed by 
the Congress's evident intent "that the measure of damages 
reflect a preference for restoration costs, at least where 
restoration is feasible and can be performed at a cost not 
grossly disproportionate to the use value of the resource."  
880 F.2d at 446; cf. S. Rep. No. 96-848, at 86 ("There is a 
need for maximum flexibility in the rulemaking proceeding, so 
that free scientific discussion will result.  Only through this 
type of discussion will the agencies be adequately prepared to 
select the most accurate and credible damage assessment 
methodologies available.").  In light of the legislative intent to 
confer discretion as to the choice of an appropriate measure 
of damages, we assess DOI's interpretation of subsection 
301(c)(2) under step two of Chevron.

     DOI has defined certain key terms in its regulations:

          Injury means a measurable adverse change, either 
     long- or short-term, in the chemical or physical quality or 
     the viability of a natural resource resulting either direct-
     ly or indirectly from exposure to a discharge of oil or 
     release of a hazardous substance, or exposure to a prod-
     uct of reactions resulting from the discharge of oil or 
     release of a hazardous substance.  As used in this part, 
     injury encompasses the phrases "injury," "destruction," 
     and "loss." ...

* * *

________
     12 NAM does not argue that the Type A rule omits consideration 
of "use value," which is apparently provided by the Compensable 
Value Submodel.  See 1996 Type A rule, 61 Fed. Reg. at 20,566-67.



          Replacement or acquisition of the equivalent means 
     the substitution for an injured resource with a resource 
     that provides the same or substantially similar ser-
     vices....

* * *

          Restoration or rehabilitation means actions undertak-
     en to return an injured resource to its baseline condition, 
     as measured in terms of the injured resource's physical, 
     chemical, or biological properties or the services it previ-
     ously provided....

43 C.F.R. ss 11.14(v) (emphasis added), 11.14(ii), 11.14(ll) 
(1996).13  Relying on these definitions, DOI contends that its 
Restoration Submodel--which considers the costs and bene-
fits of replacing an injured resource (e.g., restocking fish) 
against the costs and benefits of restoring the resource 
through natural recovery (e.g., allowing spawning and other 
________
     13 While DOI's regulations equate replacement with acquisi-
tion, the Congress apparently believed that the terms as used in 
CERCLA subsection 107(f)(1) had somewhat different meanings:

     [T]he primary purpose of the resource damage provisions of 
     CERCLA is the restoration or replacement of natural re-
     sources damaged by unlawful releases of hazardous substances.  
     However, ... a situation could arise in which the amount of 
     damages caused by a release of hazardous substances is in 
     excess of the amount that could realistically or productively be 
     used to restore or replace those resources....

          The Committee therefore intends [that] any excess funds 
     recovered shall be used, in such an instance, for the third 
     purpose spelled out in the language of the amendment, which is 
     'to acquire the equivalent of the damaged resource.'  ... The 
     Committee expects that any such acquisition would provide 
     resources of an equivalent nature at a location as near as 
     reasonably possible to the site at which the damages occurred.

H.R. Rep. No. 99-253, pt. 4 at 50 (1985).  Because we conclude that 
subsection 107(f)(1) does not speak directly to the issue of whether 
the Type A procedures must consider replacement and acquisition 
values when calculating damages under subsection 301(c)(2), howev-
er, we do not find in this passage an intent to assign replacement 
and acquisition independent meanings in subsection 301(c)(2).



natural processes to replace destroyed fish stocks)--satisfies 
the subsection 301(c)(2) requirement that the Type A regula-
tions consider "replacement value." 14  See, e.g., The 
CERCLA Type A Natural Resource Damages Assessment 
Model for Coastal and Marine Environments, Technical Docu-
mentation, Vol. 1, s 5.4.3.  DOI therefore reasons that its 
decision not to develop independent Replacement and Acqui-
sition Submodels for its Type A calculations does not render 
its rule defective but merely less ambitious than it might have 
been--which, as we have previously held, is not a ground for 
reversal.  See Colorado, 880 F.2d at 486 ("Despite the limited 
scope of the type A rules, DOI's actions are a sustainable 
response to an ambiguous statutory mandate in an area of 
scientific uncertainty.").

     NAM, on the other hand, contends that DOI's consideration 
of replacement values is insufficient to satisfy subsection 
301(c)(2) and, in any event, DOI's computer submodels do not 
meet the requirements of subsection 107(f)(1) because they 
wholly fail to consider acquisition values.  Regarding the 
latter, because the Congress has omitted any reference to 
acquisition values in subsection 301(c)(2), DOI reasonably 
accords significance to the omission and interprets it not to 
require consideration of off-site, acquisition alternatives to 
restoration.  Nor can our decision in Colorado be read to 
command a different result.  There, we held that DOI's 
failure to include "replacement or restoration values in its 
type A procedures" contravened "the clear mandate of Con-
gress as interpreted in Ohio." 880 F.2d at 491 (emphasis 
added).  We did not then, and we do not now, conclude that 
subsections 301(c)(2) and 107(f)(1) require the regulations to 
consider acquisition values.
________
     14 Replacement or acquisition may be the only feasible remedies if 
the natural resources have been destroyed or irreparably injured.  
See 1996 Type A rule, 61 Fed. Reg. at 20,601 ("[T]he model 
calculates a loss and allows only one-to-one replacement, with 
correction for restocking survival, of missing individuals....  The 
[habitat restoration] models assume that all fish and shellfish killed 
are restocked, if stocks are available.") (emphasis added;  quoted 
sentences from responses to two different comments).



     Finally, although DOI's final rule does an imperfect job of 
explaining how its Type A procedures incorporate consider-
ation of replacement values--which it seems to refer to as 
"active habitat restoration" costs, see 1996 Type A rule, 61 
Fed. Reg. at 20,601-02--any explanatory deficiencies can be 
remedied by DOI at the next biennial review.  Accordingly, 
we conclude that DOI's Type A rule satisfies the requirement 
of subsection 301(c)(2) that it "take into consideration ... 
replacement value."  Consistent with our earlier holding, its 
interpretation ensures "that the measure of damages reflect a 
preference for restoration cost, at least where restoration is 
feasible and can be performed at a cost not grossly dispropor-
tionate to the use value of the resource."  Ohio II, 880 F.2d 
at 446.

                     C. Relation of Restoration Actions 

                            to Resource "Services"


     NAM next asserts that DOI's Type A submodels are 
arbitrary and capricious--i.e., violate 5 U.S.C. s 706(2)(A)--
because they do not evaluate restoration alternatives in terms 
of the effect such action may (or may not) have on natural 
resource "services."  See supra note 4.  As DOI properly 
notes, however, NAM failed to raise this argument in the 
rulemaking proceedings below, and we find no reason to 
excuse NAM's failure to exhaust its administrative remedies.

     NAM contends that because the relationship between ser-
vices and restoration was "a general point applicable to any 
NRD assessment," because it "had been emphasized re-
peatedly in prior rulemakings," because comments in the 
rulemaking regarding the Compensable Value Submodel indi-
cated that the relationship between resource services and 
NRD was essential in developing "nonconsumptive wildlife 
values" and because "other documents in the record high-
lighted the services concept," DOI was given a "fair opportu-
nity" to consider the issue below.  Failing that, NAM argues 
that we should exercise our discretion and excuse NAM's 
failure to exhaust.  NAM Reply Br. at 10-11.



     The fact that, buried in hundreds of pages of technical 
comments NAM submitted, some mention is made of the 
resource services concept and its relation to compensable 
values (rather than restoration alternatives) is insufficient to 
preserve the issue for review on appeal.  "Our cases ... 
require complainants, before coming to court, to give the 
[agency] a fair opportunity to pass on a legal or factual 
argument."  Washington Ass'n for Television & Children v. 
FCC, 712 F.2d 677, 681 (D.C. Cir. 1983) (emphasis added;  
quotation marks omitted); accord Omnipoint Corp. v. FCC, 
78 F.3d 620, 635 (D.C. Cir. 1996) ("As a general rule, claims 
not presented to the agency may not be made for the first 
time to a reviewing court."); United States v. L.A. Tucker 
Truck Lines, 344 U.S. 33, 37 (1952) ("Simple fairness ... 
requires as a general rule that courts should not topple over 
administrative decisions unless the administrative body not 
only has erred but has erred against objection made at the 
time appropriate under its practice.").  Thus, we decline to 
find that scattered references to the services concept in a 
voluminous record addressing myriad complex technical and 
policy matters suffices to provide an agency like DOI with a 
"fair opportunity" to pass on the issue.

     Nor do we find any ground to excuse NAM's failure to urge 
its objection below.  The fact that the Kennecott decision was 
not known on the date the comment period closed is unavail-
ing.  Kennecott did not suggest a new basis for challenging 
DOI's Type A rule; it simply reaffirmed that an agency's 
regulations must be internally consistent to guard against 
double recovery.  88 F.3d at 1220 ("In invalidating the regu-
lations, we do not mean to suggest that CERCLA requires or 
forbids any particular measure of damages.  The problem 
here is not with the standard adopted, but with the consisten-
cy between the language of the regulations and the pream-
ble's explanation of what Interior did.") (emphasis added).15
________
     15 American Maritime Association v. United States, 766 F.2d 
545, 566 n.30 (D.C. Cir. 1985), is inapposite.  There the agency 
made a significant change between its proposed rule and the final 
interim rule and thus the complainant did not have the opportunity 


                        D. Lost Assimilative Capacity


     Continuing its attack on the content and function of DOI's 
Restoration Submodel, NAM next argues that DOI's inclusion 
of calculations for lost "assimilative capacity"--i.e., the pre-
release ability of an environment "to repair itself by digest-
ing, degrading, transforming, absorbing, or otherwise elimi-
nating the pollutants placed in it," 1996 Type A rule, 61 Fed. 
Reg. at 20,599--contravenes CERCLA.  It contends that 
such losses are "unduly speculative" because there may never 
be another release of the same or similar hazardous sub-
stances in the affected environment and, even if they are not 
overly speculative, DOI's calculation methodology is funda-
mentally flawed.  Both contentions are without merit.

     Subsection 301(c)(2) requires the Type A and Type B 
regulations to "take into consideration ... [the] ability of the 
ecosystem or resource to recover."  42 U.S.C. s 9651(c)(2).  
Consideration of lost assimilative capacity meets the com-
mand by assessing the cumulative effects a release may have 
on a resource's ability to recover and by preventing erosion of 
baseline conditions.  Thus, DOI's interpretation of subsection 
301(c)(2) to permit assessment of lost assimilative capacity 
damages is plainly not unreasonable and instead is consistent 
with (if not required by) the Congress's intent to recover for 
the full damages resulting from a release.  See Ohio II, 880 
F.2d at 464 (CERCLA intends recovery for all properly 
calculated losses and all kinds of losses reasonably ascribed to 
release); Colorado, 880 F.2d at 490-91 (similar); cf. S. Rep. 
No. 96-848, at 14 (one reason CERCLA was enacted was 
shortcomings of common law and statutory remedies in recov-
ering full compensation).  Moreover, contrary to NAM's con-
tentions, the stand-by nature of the resource service does not 
make it speculative:  "The assimilation of pollutants is a real 
service provided by natural resources and is well-founded in 
scientific literature."  1996 Type A rule, 61 Fed. Reg. at 
20,599.  Indeed, the fact that such assimilative capacity ser-
________
to object to the change before seeking judicial review.  Here 
nothing in the services-restoration relationship was substantively 


vice may be called on only in the contingency of a future 
release does not render the losses any more speculative than 
other kinds of contingent losses for which damages may be 
assessed.  Cf. Ohio II, 880 F.2d at 474-81 & nn.72-77 (up-
holding use of contingent valuation methodologies, including 
assessments of option and existence values, assuming re-
sources may never be visited or used but recognizing stand-
by value to their existence); General Elec. Co. v. United 
States Dep't of Commerce, 128 F.3d 767, 772-74 (D.C. Cir. 
1997) (upholding NOAA's use of contingent valuation methods 
in which individuals assign value to resources "even if they 
never plan to make active use of them").16

     Nor do we find error in DOI's decision to calculate the 
monetary loss resulting from a diminution in assimilative 
capacity by extrapolating from the costs of dredging contami-
nated sediment in a nearby area.  The standardized and 
simplified nature of Type A procedures necessarily dictates 
that they rely on data extrapolations to assign values to 
particular items of loss.  Thus, while we agree with NAM 
that (for example) using dredging cost figures from Green 
Bay to calculate restoration costs in Chicago may not be the 
most accurate method of calculating costs, it is neither unrea-
sonable nor arbitrary and capricious in the context of Type A 
assessments.  Moreover, the alternative that NAM apparent-
ly urges--barring recovery for such loss absent specific data 
on restoration costs for each potential release site--is incon-
________
altered between the notice of proposed rulemaking and the final 
rule.

     16 In addition, the amended Type A rule does not permit recovery 
of lost assimilative capacity in every circumstance.  Loss is calculat-
ed "only when there are releases that generate economic damages 
related to mortality or loss of production."  See 1996 Type A rule, 
61 Fed. Reg. at 20,599.  While an initial programming error permit-
ted the calculation of such loss in cases where the submodels 
predicted no damages related to mortality or loss of production, 
DOI has since corrected the error.  See Revisions to 1996 Type A 
rule, 62 Fed. Reg. at 60,457-58.  Thus, NAM's suggestion that 
including lost assimilative capacity in the submodels ensures per se 
damages in the event of a release is mistaken;  only if mortality and 
production thresholds are exceeded will assimilative capacity loss be 
included in the damages claim.



sistent with the remedial objectives of CERCLA and requires 
that Type A procedures provide greater precision in their loss 
measurements than CERCLA can reasonably be deemed to 
require.17

                       E. Economic Rent for Commercial 

                          Fishing and Hunting Losses


     NAM next assails DOI's inclusion of "economic rent" losses 
in its Compensable Value Submodel.18  Its main argument is 
________
     17 Nor does this conclusion make a PRP an insurer for future 
releases as NAM contends.  Each subsequent PRP will be respon-
sible for restoring assimilative capacity losses caused by a release 
for which it is liable under 42 U.S.C. s 9607(a).  Were we to adopt 
NAM's interpretation, future PRPs would be responsible for losses 
to natural resources that were greater (because of decreased assi-
milative capacity caused by predecessor PRP) than they might 
otherwise have been.  We can find nothing, nor has NAM referred 
us to anything, in CERCLA that requires DOI to favor the current 
PRP over a future PRP.  Again, the fact that traditional tort 
remedies might suggest a different allocation of risks is not disposi-
tive:  "We have already noted our disagreement with the proposition 
that the strictures of the common law apply to CERCLA."  Ohio 
II, 880 F.2d at 476.

     18 "Economic rent" in this context does not refer to profits earned 
in non-competitive markets.  Rather, DOI defines "economic rent" 
as "the excess of total earnings of a producer of a good or service 
over the payment required to induce the producer to supply the 
same quantity currently being supplied."  Natural Resource Dam-
age Assessments, 51 Fed. Reg. 27,674, 27,691 (1986); 1996 Type A 
rule, 61 Fed. Reg. at 20,603 ("In other words, economic rent for 
commercially harvested resources is the fee that commercial har-
vesters could pay to the government and still find the harvesting 
economically feasible.").

     Because DOI assumes that the small releases for which Type A 
procedures may be used will generally not cause commercial hunt-
ers and fishers to abandon or downsize their enterprises, any 
harvesting losses produced by a release will in fact represent 
"economic rent."  See 1996 Type A rule, 61 Fed. Reg. at 20,604.  
NAM does not challenge the reasonableness of the assumption and 


that commercial fishing and hunting losses are injuries of a 
"private" nature for which CERCLA does not permit recov-
ery.  According to NAM, recovery for such losses, under the 
guise of seeking compensation for losses of imputed rent that 
a trustee might collect for the privilege to fish and hunt, is 
ultra vires.  Further, NAM contends that "DOI's calculation 
of the amount of damages resulting from lost economic rent is 
based on wholly speculative assumptions."  NAM Br. 37.  
DOI's responses are twofold:  (1) NAM's challenge is time-
barred because economic rent losses have been a feature of 
DOI's Type B rules since 1986 and were a feature of DOI's 
1987 Type A rule; and (2) NAM's arguments are based on 
the mistaken premise that all commercial hunting and fishing 
losses represent "private" losses.

     DOI's timeliness defense fails here for the same reasons 
that it failed with respect to NAM's challenge to the absence 
of a "reality check" in the Type A procedures:  the change in 
"regulatory context" and stakes caused by the addition of 
Type A procedures for Great Lakes environments and by the 
substantial alterations in the procedures for coastal and ma-
rine environments constructively reopened this aspect of the 
procedures to challenge.

     Regarding the merits, NAM's challenge is apparently pred-
icated on the assumption that because commercial fishing and 
hunting enterprises have heretofore not been charged fees for 
the full value of their entitlement to fish and hunt in public 
aquatic environments covered by the Type A procedures, the 
entitlement is a private rather than a public one.  We do not 
agree.

     It is true that CERCLA does not permit private parties to 
seek recovery for damages to natural resources held in trust 
by the federal, state or tribal governments nor does it allow 
public trustees to recover for damages to private property or 
other "purely private" interests.  See Ohio II, 880 F.2d at 460 
("The legislative history of CERCLA further illustrates that 
damage to private property--absent any government involve-
________
we see nothing in the record to suggest that DOI's conclusion 
resulting from its assumption is unreasonable either.



ment, management or control--is not covered by the natural 
resource damage provisions of the statute."); Exxon Corp. v. 
Hunt, 475 U.S. 355, 375 (1986) (compensation to "third parties 
for damage resulting from hazardous substance discharges 
... [is] clearly beyond the scope of CERCLA").  Determin-
ing whether a particular loss is "private" or "public" is the 
task with which we are faced here.19

     CERCLA defines natural resources to encompass

     land, fish, wildlife, biota, air, water, ground water, drink-
     ing water supplies, and other such resources belonging 
     to, managed by, held in trust by, appertaining to, or 
     otherwise controlled by the United States (including the 
     resources of the fishery conservation zone established by 
     the Magnuson-Stevens Fishery Conservation and Man-
     agement Act [16 U.S.C.A. ss 1801 et seq.]) any State or 
     local government, any foreign government, any Indian 
     tribe, or, if such resources are subject to a trust restric-
     tion on alienation, any member of an Indian tribe.

42 U.S.C. s 9601(16) (emphasis added).  As noted earlier, 
resources must be under the stewardship of a trustee before 
damages can be assessed for their injury, loss or destruction.  
See supra note 1.  A release of hazardous substances in the 
Great Lakes or covered coastal and marine environments that 
kills fish or game or makes it inedible or unusable for 
commercial or other purposes injures natural resources.  Cf. 
Alaska Sport Fishing Ass'n v. Exxon Corp., 34 F.3d 769, 773 
(9th Cir. 1994) ("A state has a sovereign interest in natural 
resources within its boundaries.").

     Because public trustees do not currently charge commer-
cial harvesters access fees above those required to cover ad-
________
     19 NAM's reliance on Satsky v. Paramount Communications, 
Inc., 7 F.3d 1464 (10th Cir. 1993), is misplaced.  The Tenth Circuit 
held that suits for injuries to "purely private interests" could not be 
barred by a state's recovery of public losses.  Id. at 1470.  It also 
held, however, that to the extent the "claims are for injuries to 
interests which all citizens hold in common, and for which the State 
has already recovered, the [former] judgement ... acts as a bar."  
Id.



ministrative and registration costs, NAM reasons that the 
harvesters have converted these public resources into private 
property so that any adverse effect a release may have on 
harvesting activities represents a "purely private" loss for 
which the trustee cannot recover.  The fact that commercial 
hunting and fishing operations are not presently paying 
something (or at least more) for the privilege to exploit public 
fish and game stocks does not mean that they have converted 
the stocks into private property.  Rather, the public custodi-
ans of the resources have determined that the public interest 
is served by refraining from charging the commercial enter-
prises for harvesting the public fish and game stocks.  Thus 
we do not find DOI's conclusion--that if the public cannot use 
its resources to foster commercial enterprises, the value of 
the resources to the public (as well as to the enterprises) has 
been diminished--unreasonable.  See 1996 Type A rule, 61 
Fed. Reg. at 20,604 ("The governmental regulation of fish and 
wildlife harvest implies a public concern that these resources 
be managed in order to sustain their contribution to economic 
productivity.").

     Nor does recovery of imputed rent losses run afoul of the 
subsection 107(f)(1) prohibition on double recovery.  As the 
regulations explain, "[f]or minor releases where damages may 
be relatively low and data establishing injury and causation 
may be difficult to obtain, ... it is unlikely that commercial 
harvesters will go to the expense and trouble to pursue a 
legal claim."  Id. at 20,604.  In addition, "in some cases 
commercial harvesters will not have a private cause of action 
or their recoveries may be subject to geographic or temporal 
limitations."  Id.  Given the nature of the release for which 
damages are assessed, the likelihood of double recovery is 
minimal.  If a commercial harvester does sue and succeeds in 
recovering the public's imputed rent as part of its lost profits, 
however, the regulations bar the trustee from including such 
losses in its calculation of NRD.  Id.;  43 C.F.R. s 11.44(d) 
(1996).  Moreover, once a state or other public trustee recov-
ers such damages, a private party will be barred by res 
judicata from later seeking recovery for the same public 
losses.  See Alaska Sport Fishing, 34 F.3d at 774 ("[T]he 


United States and the state of Alaska, acting as government 
trustees, have already recovered for the very same damages 
plaintiffs now seek here....  Thus, under the doctrine of res 
judicata, plaintiffs are barred from asserting such claims in a 
second suit.").  Accordingly, DOI's inclusion of economic rent 
losses in its Type A submodels cannot reasonably be deemed 
to pose a likely risk of double recovery.

     Finally, DOI's ancillary attack on the reasonableness of the 
assumptions underlying the submodel's calculation of econom-
ic rents also fails.  Once again, we can find nothing unreason-
able or irrational in the means by which DOI's Compensable 
Value Submodel calculates lost economic rents resulting from 
a release.  The fact that such imputed rents have not been 
collected previously does not ipso facto make their valuation 
unduly speculative as the assumption that minor spills will 
likely not affect commercial fishing and hunting appears 
reasonable.  In view of an unchanged activity level, DOI's 
derivative conclusion that the harvesting losses represent an 
appropriate proxy for lost economic rent cannot be viewed as 
irrational.  Again, in technical matters it is not our role to 
second guess the agency's expert judgments if they are 
reasonable and adequately explained.  See Troy Corp., 120 
F.3d at 283; American Iron & Steel, 115 F.3d at 1004-05.

              F. "Best Available Procedures" for Calculating NRD


     NAM next seizes on the "best available procedures" lan-
guage of subsection 301(c)(2)--i.e., the Type A and B regula-
tions "shall identify the best available procedures to deter-
mine such [natural resource] damages, including both direct 
and indirect injury, destruction, or loss"--and contends that 
because DOI used certain inapplicable, outdated or methodo-
logically suspect studies in developing its Type A submodels, 
it violated CERCLA's direction to use the "most accurate and 
credible damage assessment methodologies available."  S. 
Rep. No. 96-848, at 86.  NAM also suggests that because a 
Type A assessment enjoys a rebuttable presumption of cor-
rectness under subsection 107(f)(1), DOI is under a height-


ened obligation to demonstrate the validity and rationality of 
its modeling assumptions and their empirical support.20

     Technical attacks on the Type A submodels are assessed 
under the deferential standard that applies when an agency's 
scientific and technical judgment is at issue.  See generally 
Troy Corp., 120 F.3d at 283; American Iron, 115 F.3d at 
1004-05.  The "best available procedures" language is neither 
defined by statute nor self-defining and so we apply Chevron 
step two in assessing whether DOI's decision to include 
certain studies complies with subsection 301(c)(2)'s require-
ment that it "identify the best available procedures."  See 
generally Ohio II, 880 F.2d at 476-78 (concluding DOI's 
adoption of contingent valuation methodologies was "best 
available procedure" because "the risk of overestimation has 
not been shown to produce such egregious results as to 
justify judicial overruling of DOI's careful estimate of the 
caliber and worth of CV methodology").

     NAM's arguments regarding the additional burden an 
agency bears when using calculations whose results enjoy a 
rebuttable presumption of correctness is beside the point 
because the presumption has been established by the Con-
gress, not the agency.  See General Electric, 128 F.3d at 771-
72 ("Chemical Manufacturers [applicable test], however, ap-
plies only to rebuttable presumptions created by agencies and 
has no applicability where, as here, Congress created the 
presumption.").

     NAM's argument is also fatally flawed because it reads 
"available" out of the subsection 301(c)(2) requirement to 
"identify the best available procedures to determine" dam-
ages, a disfavored interpretation under both Chevron steps.  
See American Fed'n of Gov't Employees v. FLRA, 798 F.2d 
1525, 1528 (D.C. Cir. 1986); cf. Reiter v. Sonotone Corp., 442 
U.S. 330, 339 (1979).  Thus, while the studies upon which DOI 
________
     20 NAM also claims that the inclusion of "lost assimilative capaci-
ty" and "economic rent" variables in the Type A submodels violates 
the "best available procedures" mandate.  As discussed above, 
however, we find nothing unreasonable or otherwise insufficient in 
DOI's use of these variables.



relies may not use the "best" methodologies and techniques, 
they appear to be the "best available," which is all that 
CERCLA requires.21

     DOI used a number of screening criteria that studies had 
to meet before they became part of its submodels' databases.  
See 1996 Type A rule, 61 Fed. Reg. at 20,571 ("The Depart-
ment used only studies that:  (1) Were based on an extensive 
literature review and consultations with relevant governmen-
tal agencies; (2) reasonably represented the natural resource 
and public use under investigation; (3) contributed to a 
reasonable representation of the different regions included in 
the model; (4) were conducted by a recognized university-
associated researcher or established consulting firm; and (5) 
used appropriate valuation methodologies.").  These criteria 
assisted DOI in determining which studies were sufficiently 
reliable to use in its computer submodels.  Thus, DOI's 
decision to use studies assigning values to recreational salmon 
and trout fishing in several western states in order to develop 
comparable values for such activities in the Great Lakes 
region was not unreasonable in view of the fact that there 
were no other studies available that satisfied the screening 
criteria and focused on the Great Lakes.  Similarly, the fact 
that DOI used nine freshwater fishing studies, in addition to 
twenty-one salt water fishing studies, to produce averaged 
values for recreational fishing in coastal and marine environ-
ments can hardly be viewed as irrational or unreasonable.  
Again, DOI reasonably determined that the "best available" 
values could more accurately be developed by averaging a 
________
     21 Had DOI chosen not to assign any values to damages because 
of the age, methodologies, etc. of certain studies, it would have less 
fully effected a fundamental purpose of CERCLA--i.e., to ensure 
the full recovery of the costs associated with a release of hazardous 
substances.  Cf. Ohio II, 880 F.2d at 478 (concluding that in light of 
"CERCLA's preference for restoration" it would not make sense to 
insist on more stringent pre-release contingent valuation surveys to 
satisfy "best available procedures" requirement of subsection 
301(c)(2));  Colorado, 880 F.2d at 490-91; S. Rep. No. 96-848, at 14 
(observing one reason CERCLA was enacted is that "the compensa-
tion ultimately provided ... is generally inadequate").



broader range of values than the saltwater studies alone 
would have allowed.

     Further, DOI's decision to arrive at average recreational 
values for the Great Lakes beaches by including four studies 
of recreational values for beaches in Hawaii and Florida, in 
addition to seven other studies of non-Great Lakes beach 
values, appears reasonable, especially given the absence of 
any suitable studies of Great Lakes beaches themselves.  
Once again, averaging values from such geographically di-
verse studies appears to have been a rational way in which to 
arrive at the "best available" values.22

     We also find no error in DOI's decision to use older studies 
that rely on contingent valuation or travel cost methodologies.  
Again, DOI was confronted with a choice:  utilization of older, 
less methodologically reliable studies to assign values for 
particular losses, guesswork to produce the appropriate val-
ues or their exclusion from its computer submodels.  DOI's 
expert judgment that it was best to proceed in reliance on 
available studies is plainly a permissible interpretation of the 
subsection 301(c)(1) charge to "identify the best available 
procedures to determine" NRD.

     We also find reasonable DOI's decision to include wildlife 
viewing losses in its submodels.  Because no studies existed 
that quantified or qualified the correlation between wildlife 
population losses and wildlife viewing losses, DOI reasonably 
assumed a one-to-one, linear correlation.  In the absence of 
any studies to suggest that such linear assumptions overstate 
(or understate) loss, we can find no error in DOI's determina-
tion that population losses would typically result in a corre-
sponding loss in viewing opportunities.

     Finally, we decline to second-guess DOI's technical judg-
ments as to toxicity values for certain types of releases.  See 
________
     22 Also, as noted in DOI's Brief, had the Florida and Hawaii 
studies been excluded, the average values in the Type A submodels 
would have been affected by a mere $.03 per day; hardly a basis to 
conclude that inclusion of the studies skewed the values in DOI's 
submodels.  DOI Br. at 43.



Troy Corp., 120 F.3d at 283; American Iron, 115 F.3d at 
1004-05.  The fact that DOI's and NAM's experts disagree on 
the proper toxicity values for certain substances and concen-
trations does not render DOI's judgment defective.23  Cf. 
Ohio II, 880 F.2d at 465 (rejecting challenge to use of 
discount rate in calculating net present value of loss because 
"petitioners have given us no reason to substitute our judg-
ment for that of Interior and of the Office of Management 
and Budget, whose circular provided the ten percent figure 
chosen").  Accordingly, once again we conclude that DOI's 
reconciliation of the "best available procedures" language and 
"full recovery" goals of CERCLA is reasonable and therefore 
sustainable.  See Ohio II, 880 F.2d at 441, 464.

                     G. Application of Type A and Type B

                          Procedures to Same Release


     NAM next challenges DOI's Type A rule because it permits 
trustees to use both Type A and Type B procedures to 
calculate NRD for the same release, which (1) violates the 
clearly expressed intent of the Congress that the two types of 
procedures be "alternative" rather than complementary pro-
cedures, (2) conflicts with the use of average valuations in the 
Type A computer submodels and (3) contravenes the regula-
tory requirement that Type B procedures not be employed to 
calculate compensable values until they have been validated 
for a specific incident by a "reality check."  DOI responds 
that NAM's second argument is not ripe for resolution and 
that all of NAM's arguments are otherwise lacking in merit.  
We agree that NAM's arguments are without merit.24
________
     23 NAM also criticizes DOI for including toxicity values for cop-
per, zinc and mercury despite DOI's intent to remove such toxicity 
values for pure metals from its submodels' databases.  See 1996 
Type A rule, 61 Fed. Reg. at 20,591.  DOI has since acknowledged 
the error and removed the values from its submodels.  See Revi-
sions to 1996 Type A rule, 62 Fed. Reg. at 60,458.

     24 DOI also appears to suggest that at least a portion of NAM's 
challenge is untimely because the 1987 Type A rule allowed com-
bined use of Type A and B procedures in certain circumstances.  


               (1) Legislative intent and combined application 

                       of Type A and Type B procedures


     Subsection 301(c)(2) of CERCLA, as discussed and quoted 
above (see supra page 5), distinguishes, both textually and 
structurally, between Type A "standard procedures" and 
Type B "alternative protocols for conducting assessments in 
individual cases."  42 U.S.C. s 9651(c)(2).  The distinctions 
were intended:

          This subsection calls for the promulgation of two types 
     of regulations.  First, a simplified type of regulation 
     [Type A] is necessary to effectively deal with damage 
     assessment in most 'minor' releases of hazardous materi-
     als....

          The other type of regulations [Type B] would be 
     employed in large or unusually damaging releases and 
     would be used to guide the site-specific damage assess-
     ment.  Such a regulation would contain protocols for 
     field assessment of the type and extent of short- and 
     long-term damage and methodologies for determining 
     their value.

          The protocols for field assessments should provide 
     uniform instructions that will allow for thorough site 
     investigation in a cost-effective manner.  Sampling and 
     statistical procedures should be clearly defined.  The 
     methods for determining the geographical extent of dam-
     age should also be enumerated.  It is the intent of the 
     legislation that these protocols be designed to accommo-
________
See DOI Br. 48 n.17.  We reject the argument for the same reason 
we rejected it with respect to the challenges discussed supra in 
Parts II.A and II.E.  Further, we note that the circumstances in 
which a combined Type A and Type B assessment may be used 
have been significantly expanded by the 1996 rule compared to the 
1987 rule.  Compare 1996 Type A rule, 61 Fed. Reg. at 20,610 with 
1987 Type A rule, 52 Fed. Reg. at 9048-49.  Moreover, DOI 
appeared to reopen the issue:  "The Department explicitly limited 
this rulemaking to four issues:  ... the conditions for combined use 
of type A and type B procedures;...."  1996 Type A rule, 61 Fed. 
Reg. at 20,570.



     date the majority of potential release sites, including 
     coastal estuaries, open water, freshwater rivers, lakes 
     and wetlands.

S. Rep. No. 96-848, at 86; accord Colorado, 880 F.2d at 487 
("[A]lthough Congress did not have a specific intent regard-
ing the proper scope of type A rules, it envisioned generally 
that type A rules would cover most minor releases and type B 
rules would cover large or unusually damaging releases.").

     Nevertheless, subsection 107(f)(2)(C) does not differentiate 
between the two types of procedures with respect to the 
rebuttable presumption:  "Any determination or assessment 
of damages to natural resources ... made by a Federal or 
State trustee in accordance with the regulations promulgated 
under section 9651(c) of this title shall have the force and 
effect of a rebuttable presumption."  42 U.S.C. 
s 9607(f)(2)(C) (emphasis added).  Significantly, the Congress 
indicated that the rulemaking required by subsection 
301(c)(2) should emphasize flexibility and development of a 
variety of measurement tools for a trustee's use:

          Investigations by the Committee on Environmental 
     and Public Works revealed the need for an improved, fair 
     and expeditious mechanism for dealing with natural re-
     source damages caused by releases of hazardous materi-
     als.  The principal hindrance to attaining such a mecha-
     nism was the absence of a standardized system for 
     assessing such damages which is efficient as to both time 
     and cost.

          The reported bill provides ... that ... agencies should 
     standardize a process through regulation for assessing 
     damages to those resources.  This could be done after a 
     thorough review of alternatives for damage assessment.  
     This approach will focus on scientific debate concerning 
     damage assessment in the rulemaking process and result 
     in a decision regarding the best simplified procedures for 
     making accurate and defensible assessments of resource 
     damages.

* * *



          The rulemaking should produce a range of products.  
     At one end will be simplified assessment procedures 
     requiring a minimum of fieldwork and using a combina-
     tion of habitat values, species values, and other simplified 
     methods.  Such procedures would be of value in dealing 
     with minor releases.  At the other end of the range 
     would be damage assessment protocols to be used when-
     ever the extent of natural resource damage is substantial 
     and extensive fieldwork becomes necessary.  The assess-
     ment procedures and protocols should include a choice of 
     acceptable damage assessment methodologies to be em-
     ployed with the evidentiary status of a rebuttable pre-
     sumption accorded to the results when the protocols are 
     followed.

          There is a need for maximum flexibility in the rule-
     making proceeding, so that free scientific discussion will 
     result.  Only through this type of discussion will the 
     agencies be adequately prepared to select the most accu-
     rate and credible damage assessment methodologies 
     available.

S. Rep. No. 96-848, at 85-86 (emphasis added).

     By using Type A procedures and selectively supplementing 
them with certain low-cost and expeditious Type B proce-
dures, DOI is able to arrive at a more complete assessment of 
damages at less cost and in less time than a full-blown Type 
B assessment would likely require.  Cf. 1996 Type A rule, 61 
Fed. Reg. at 20,577 ("[T]rustees should not be forced to 
choose between foregoing compensation for a public loss not 
addressed by the type A submodel on the one hand and 
funding a full-scale, time-consuming, labor-intensive type B 
assessment of all injuries on the other hand.").

     Nor does the combined use of Type A and Type B proce-
dures pose a risk of double recovery.  The regulations limit 
the use of supplemental Type B procedures to the determina-
tion of "damages for injuries or compensable values that do 
not fall into the categories addressed by the type A proce-
dure."  43 C.F.R. s 11.36(a) (1996).  In addition, a trustee 
who elects to use both types of procedures must document in 


the Assessment Plan how double recovery is to be avoided.  
Id. s 11.36(c).  Thus, if, for example, the Type A procedures 
have already produced a value for mortality losses, Type B 
procedures may not also be used to calculate that item of loss.  
We therefore find nothing unreasonable in DOI's interpreta-
tion of CERCLA subsection 301(c)(2) as permitting combined 
use of Type A and Type B procedures.25

                   (2) Average values and Type B procedures


     NAM's challenge to the combination of Type B procedures 
and the average valuations produced by Type A procedures to 
arrive at a single NRD figure is, contrary to DOI's view, ripe 
for review.  To determine ripeness we "evaluate both the 
fitness of the issues for judicial decision and the hardship to 
the parties of withholding court consideration."  Abbott Labs. 
v. Gardner, 387 U.S. 136, 149 (1967).  In applying the two- 
part test, we note that the "basic rationale" of the ripeness 
test is "to prevent the courts, through avoidance of premature 
adjudication, from entangling themselves in abstract dis-
agreements over administrative policies, and also to protect 
the agencies from judicial interference until an administrative 
decision has been formalized and its effects felt in a concrete 
way by the challenging parties."  Id. at 148-49.

     NAM's claim appears to be fit for resolution now.  NAM 
has styled its challenge as one to the lawfulness of DOI's 
decision under CERCLA to allow trustees to calculate NRD 
with combined Type A and Type B procedures and DOI's 
decision to permit the combination is indisputably final.  Cf. 
________
     25 Nor do we find problematic the fact that the rule authorizes 
Type B assessments for types of losses not captured by Type A 
procedures.  See 1996 Type A rule, 61 Fed. Reg. at 20,578 ("Finally, 
the Department believes it is appropriate to revise the existing rule 
to allow supplemental use of type B procedures beyond resources 
not addressed in the type A submodels.  The public can experience 
significant and distinct losses associated with the same re-
source....  The Department sees no reason to impose an arbitrary 
distinction between losses associated with different resources and 
losses associated with the same resource so long as there is no 
double recovery.").


Abbot Labs., 387 U.S. at 149-50.  Moreover, the effect of 
DOI's interpretation is sufficiently concrete and immediate to 
satisfy the second prong of the Abbott Labs. test.  A trustee 
that complies with the criteria set forth in the regulation may 
now combine Type A and Type B procedures to assess 
natural resource damages resulting from a release and a PRP 
may well be required to decide whether it should force a Type 
B assessment or allow a supplemented Type A assessment to 
proceed.  Cf. id. at 152-53 (finding that because FDA com-
missioner's rule, effective upon publication, required affected 
parties to take immediate action or face possible sanctions for 
non-compliance, rule's effect was "sufficiently direct and im-
mediate as to render the issue appropriate for judicial review 
at this stage").  Thus, unlike the unripe challenge we rejected 
in Kennecott, 88 F.3d at 1223 ("The guidance offered [in rule's 
preamble] is hypothetical and non-specific;  it is not crafted as 
a concrete rule that can be applied under identified circum-
stances."), here the rules are concrete, specific and immedi-
ately effective.

     Nonetheless, once again, NAM's claim fails on the merits.  
While the Type A submodels predict losses based on certain 
averaged values, that does not mean that supplementing the 
determinations with Type B calculations for values that are 
not included in the Type A submodels will result in overesti-
mation or underestimation of damages.  Because each of the 
procedures is addressed to a different type or component of 
loss, averaged and non-averaged values are not being com-
bined to arrive at a joint loss figure for a particular type or 
component of damages.  Thus NAM's assertion that combin-
ing items of loss arrived at through averaged values with 
items developed with non-averaged values produces bogus 
total loss figures is erroneous.  Indeed, without the use of 
supplemental Type B procedures, a trustee could recover less 
than the full measure of damages sustained because certain 
values are not covered in the Type A submodels.  Therefore, 
the addition of supplemental Type B procedures should not 
alter the degree to which the total loss figures produced could 
underestimate or overestimate loss.  Moreover, we can find 
nothing in CERCLA that requires the calculation of aggre-


gate NRD either with or without averaged values but not 
with a mixture of the two.

              (3) Use of Type B procedures to assess compensable

                     value losses without "reality check"


     NAM's final argument that DOI erred in permitting the 
use of certain Type B procedures without requiring site-
specific validation also fails.  While the regulations do require 
that injury determination and quantification be performed 
anew when supplemental Type B procedures are employed to 
calculate items of loss other than compensable value, they do 
not require the same when the procedures are used to 
calculate compensable value losses not included in the Type A 
submodels.  Again, this distinction reflects DOI's expert 
judgment that the Type A causation and loss predictions are 
adequate for the purposes of injury determination and quanti-
fication in the compensable value context but not in the 
restoration submodels.  And again, we decline NAM's invita-
tion to review expert judgments the Congress has committed 
to a coordinate branch of government.  See Troy Corp., 120 
F.3d at 283; American Iron, 115 F.3d at 1004-05.

                  H. Inclusion of Non-Binding Oil Discharge 

                          Subroutines in Final Rule


     Finally, NAM contends that DOI erred by retaining model-
ing subroutines for oil and petroleum discharges, which are 
now under the jurisdiction of NOAA and governed by regula-
tions implementing OPA.26 Because we find that NAM lacks 
standing to bring the claim, we do not reach the merits.
________
     26 With respect to oil discharges, DOI's regulations provide:

          The Department began developing the type A procedures 
     before the enactment of OPA and, thus, originally included 
     both hazardous substances and oil in the [Type A] algorithms 
     and databases.  The Department has worked closely with 
     NOAA during the development of the type A procedures.  
     During its rulemaking, NOAA indicated it would allow use of 


     "[T]he standing doctrine requires would-be litigants to 
demonstrate an (1) injury in fact; (2) which is caused by, or is 
fairly traceable to, the alleged unlawful conduct; and (3) 
which is likely to be redressed by a favorable decision of the 
court."  Animal Legal Defense Fund v. Glickman, 130 F.3d 
464, ---, 1997 WL 753903, at *2 (D.C. Cir. Dec. 9, 1997).  
Moreover, "[t]he party invoking federal jurisdiction bears the 
burden of establishing these elements, ... and may not 
pursue its claims before the federal judiciary if it fails to 
demonstrate any one of them."  Id.

     NAM's claim here is that DOI could not support NOAA's 
rulemaking under OPA by retaining subroutines and data it 
had developed while it retained jurisdiction over oil and 
petroleum discharges because DOI had no authority to pub-
lish such material in the Federal Register.  Rather, according 
to NAM, NOAA had to recreate the submodels itself and 
subject its version of DOI's submodels to additional notice 
and comment.  See Appellant Br. 48.  NAM has two standing 
problems with the argument.  First, NAM has wholly failed 
to identify how it or its members have suffered injury in fact 
that is concrete and imminent.  See Bennett v. Spear, 117 
________
     the Department's type A procedures under the OPA regula-
     tions....

          NOAA's final rule states that trustees may use "[m]odel-
     based procedures, including type A procedures identified in 43 
     C.F.R. part 11, subpart D," provided that any such procedure 
     meets [certain specific conditions]....

          Therefore, the Department has retained components relating 
     to oil in the final versions of the [Type A procedures], while 
     recognizing that these components are without any direct 
     regulatory effect.  The Department is also providing responses 
     to comments it received on the oil-related components of the 
     type A models.  However, the Department wishes to emphasize 
     that its regulations do not govern the assessment of natural 
     resource damages for oil discharges under OPA. Trustees who 
     wish to use the type A procedures and obtain a rebuttable 
     presumption for assessments of oil discharges must follow the 
     process established by NOAA's regulations.

1996 Type A rule, 61 Fed. Reg. at 20,561.

  

S. Ct. 1154, 1161 (1997).  The regulations plainly acknowledge 
that the retained (and revised) subroutines are without bind-
ing effect because regulation of oil and petroleum discharges 
is now the exclusive province of NOAA.  See 1996 Type A 
rule, 61 Fed. Reg. at 20,561.  Thus, NAM cannot have been 
injured by DOI's decision to publish the non-binding materi-
als.  Second and more fundamentally, NAM has failed to 
show that any injury it may have suffered is "fairly traceable" 
to DOI's decision to retain, in non-binding form, the oil 
discharge databases and subroutines.  To the extent NAM 
has a problem with NOAA's incorporation of the procedures 
into its OPA regulation without developing assessment sub-
models and databases anew and without subjecting such 
procedures to additional notice and comment, its claim is 
against NOAA, not DOI.  Cf. Animal Legal Defense Fund, 
130 F.3d at ---, 1997 WL 753903, at *3 ("In analyzing the 
'causation' element of constitutional standing, we ask whether 
it is 'substantially probable' that the challenged acts of the 
[respondent]--as opposed to some third party--caused [the 
petitioner's] particularized injury.").  Furthermore, NAM had 
an opportunity to participate in the litigation challenging 
NOAA's regulations--indeed, its counsel represented an in-
tervenor in that case.  See General Elec., 128 F.3d at 769.  
Accordingly, we find that NAM has failed to establish its 
standing to bring its oil discharge claims against DOI.

                               III. CONCLUSION


     For the foregoing reasons, we uphold DOI's Type A rule 
(Natural Resource Damage Assessments--Type A Proce-
dures, 61 Fed. Reg. 20,560 (1996) (codified at 43 C.F.R. pt. 
11)).  Accordingly, NAM's petition is

Denied.