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Natural resource damage assessment (CERCLA Type A procedure)

Interior raised the pollution-damage fast-track cap 50-fold

Summary

The Department of the Interior finalized a rule raising the dollar ceiling for its simplified "Type A" natural resource damage assessment -- the fast-track process for calculating what a company owes after a hazardous-substance release -- from $100,000 to $5 million, a fifty-fold jump, and lifted the rule's old restriction to coastal, marine, and Great Lakes sites so it now applies anywhere. Interior's own analysis of 57 settled cases from 1992 through 2023 found the new cap would have covered 36 of them; the 21 it would still exclude averaged $25.7 million in settlements. The agency projects $174 million in savings over ten years, and says at least one polluter has already volunteered to use the faster track.

By Nero · July 13, 2026

The Department of the Interior finalized a rule raising the dollar ceiling on its simplified "Type A" natural resource damage assessment procedure from $100,000 to $5 million -- a fifty-fold increase -- and removed the procedure's old restriction to coastal, marine, and Great Lakes environments, so it can now be used anywhere a hazardous-substance release occurs. The rule was published July 13, 2026 and takes effect August 12, 2026.

What the cap actually gates

When a hazardous substance is released into the environment, government "trustees" can pursue a damage claim against the responsible party to fund restoration. CERCLA gives them two tracks: Type B, an intensive, field-work-heavy assessment for individual cases, and Type A, a standardized, minimal-field-observation method whose results carry a legal "rebuttable presumption of correctness" in court. Under the prior rule, that presumption -- and Type A eligibility with it -- topped out at $100,000 in damages. The new rule raises that ceiling to $5 million, and even higher if every party, including the polluter, agrees.

Type A damage-claim cap, before vs. after
$100K -> $5M
a 50-fold increase, and no longer limited to coastal, marine, or Great Lakes sites -- usable in any environment
Projected federal-and-private savings, 2024-2033
$174M
nominal total; $152.9M discounted at 3%, $130.8M at 7%, from an estimated $17.4M/year across nine Type A assessments
Historical cases the new $5M cap would have covered
36 of 57
63% of settled 1992-2023 cases; the 21 left out averaged $25.7M in settlements, well above the new cap

How much of the past would the new cap have covered

Interior tested the threshold against its own Damage Assessment and Restoration Tracking System, a dataset of 57 settled damage cases from 1992 through 2023. A $3 million cap would have qualified 27 of those cases for the fast track; the $5 million cap Interior adopted would have qualified 36 -- about 63%. The 21 cases that would still fall outside it, requiring the slower Type B process, had a median settlement of $12 million and an average of $25.7 million, well above the new ceiling.

A higher cap sweeps in more historical settlements -- but not all of them
Of 57 settled natural resource damage cases (1992-2023), how many would qualify as fast-track "Type A" at each threshold
$3 million threshold
27
$5 million threshold (adopted)
36
$12 million threshold
42
Source: Interior, Natural Resource Damages for Hazardous Substances final rule, DARTS dataset
View data as table
Number of the 57 DARTS-tracked natural resource damage settlements (1992-2023) that would have qualified for the simplified Type A procedure at each candidate dollar threshold; Interior adopted $5 million.
$3 million threshold27
$5 million threshold (adopted)36
$12 million threshold42

The savings case, and where it comes from

Interior's cost estimate rests on labor hours: a Type B assessment takes nearly three times as long to complete as Type A, mostly in private-sector work. Valuing that time at Bureau of Labor Statistics wage rates, Interior put the burden-hour cost at roughly $3.0 million per Type B assessment against $1.0 million for Type A -- a savings of $1.9 million per case converted. Across an estimated nine Type A assessments a year, that's about $17.4 million annually, and $174 million in nominal savings over the 2024-2033 window Interior's own table projects -- $152.9 million once discounted at 3%, $130.8 million at 7%.

Projected savings shrink once future dollars are discounted
Interior's projected 10-year (2024-2033) savings from switching Type B cases to Type A, by accounting treatment
Nominal
174
Discounted at 3%
152.9
Discounted at 7%
130.8
Source: Interior, Natural Resource Damages for Hazardous Substances final rule, Table 1
View data as table
Interior's projected total savings to non-federal parties (public, private sector, states, and Tribes) from switching Type B assessments to Type A, 2024-2033, under three accounting treatments (Table 1 of the final rule).
Nominal174
Discounted at 3%152.9
Discounted at 7%130.8

The takeaway

  • The fast-track ceiling for pollution damage claims just jumped fifty-fold. $100,000 to $5 million, with no more geographic limits -- and even cases above $5 million can use the simplified process if every party, including the polluter, agrees.
  • It would have covered about two-thirds of the last three decades' settled cases. 36 of 57 in Interior's own 1992-2023 dataset -- but the 21 left out averaged $25.7 million, well above the new cap, and still require the more rigorous Type B process.
  • Interior is banking on $174 million in savings by 2033 -- built on the assumption that shifting cases from the slower, field-work-heavy Type B track to the streamlined Type A track cuts labor costs by about $1.9 million per assessment, nine times a year.

All findings are from the final rule "Natural Resource Damages for Hazardous Substances," Department of the Interior, Office of Restoration and Damage Assessment (docket DOI-2022-0016, RIN 1090-AB26), published in the Federal Register July 13, 2026 and read directly from the govinfo.gov PDF (extracted with pdftotext -layout), not a summary. The savings and case-coverage figures are Interior's own regulatory-impact analysis, required under Executive Orders 12866 and 13563 -- they are the agency's projections, not an independent audit of the rule's effects.

Sources(1) ▾
  • U.S. Department of the Interior, Office of Restoration and Damage Assessment, Natural Resource Damages for Hazardous Substances (final rule; 43 CFR Part 11, RIN 1090-AB26) (2026-07-13)Final rule published in the Federal Register, Vol. 91, No. 132, July 13, 2026 (docket DOI-2022-0016, RIN 1090-AB26), effective August 12, 2026. Read directly from the govinfo.gov Federal Register PDF (extracted with pdftotext -layout) -- the Table 1 ten-year savings table and the DARTS historical-case threshold analysis are in the preamble's Regulatory Planning and Review section, not summarized in any press release. govinfo.gov · original document
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