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The NAM petitioned the D.C. Circuit to review final regulations establishing simplified "Type A" procedures for natural resource damage assessments under the Comprehensive Environmental Response, Compensation and Liability Act. The procedures rely on complex computer modeling with very little site-specific input, and create a rebuttable presumption against potentially responsible parties, including many NAM members. The NAM argued that the regulations were invalid because (1) liability might be imposed without a showing of actual injury, (2) an assessment includes restoration without considering feasibility or cost-effectiveness, and (3) a restoration model assumes losses that are speculative and hypothetical. The D.C. Circuit court on 1/16/98 rejected the NAM arguments, concluding that the Department of the Interior's interpretation of the relevant CERCLA provisions were entitled to deference and that its damage submodels "suffice."