EPA History - Russell E. Train: Oral History Interview
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Russell E.  Train:  Oral History  Interview


Foreword

This publication is the second in a series of
oral history interviews with the
Environmental Protection Agency's
administrators and deputy administrators.
The EPA History Program has undertaken
this project in order to preserve,  distill, and
disseminate the main experiences and
insights of the men and women who have
led the agency. EPA decision-makers and
staff, related government entities, the
environmental community, scholars, and the
general public, will all profit from these
recollections. Separately, each of the
interviews will describe the perspectives of
particular leaders. Collectively, these
reminiscences will illustrate the dynamic
nature of EPA's historic mission; the
personalities and institutions which have
shaped its outlook; the context of the times
in which it has operated; and some of the
agency's principal achievements and shortcomings.

The techniques used to prepare the EPA oral history series conform to the
practices commonly observed by professional historians. The questions, submitted
in advance, are broad and open-ended,  and the answers are preserved on audio
tape. Once transcripts of the recordings  are completed, the History Program staff
edits the manuscripts to improve clarity,  factual accuracy, and logical progression.
The finished manuscripts are then returned  to the interviewees, who may alter the
text to eliminate errors made during transcription of the tapes, or during the editorial
phase of preparation.

A ooiisboratlve work stioh as this incurs; a number  of debts, Ka;hy Petrucce!!!. Director of EPA's;
Management and Crgsnizaticn Division, sought support for transcription and printing costs. John
Chainberlin, Director of the Office of Administration, provided the necessary funds. Filially, Russell Train
himself must be aoktiovyiedoed for his candid and insighlfui reflections on this formative period in EPA
history.
                       Biography
                       Unlike many conservationists, ecologists,
                       and environmentalists who commit
                       themselves to nature in their early years,
                       Russell E. Train found himself drawn to it
                       in mid-life. Like his parents - U.S. Navy
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EPA History - Russell E. Train: Oral History Interview
                                                                   Page 2 of 18
                                                             EPA Administrator Russell E. Train September
                                                             1973
Rear Admiral Charles R. Train and Errol
C. Brown - Train and his two brothers
were reared in the District of Columbia.
During the summers, however, the
nautical Trains rented a house in
Jamestown, Rhode Island, where Russell
Train was born in June 1920. Family life
may have been complicated by Admiral
Train's long absences for sea duty, but
the young brothers grew up in an
otherwise secure household.

After attending the Potomac School,
Russell Train graduated from St. Alban's
in 1937. He then enrolled at Princeton
University and in 1941  received a
Bachelor's degree in Politics. On
campus, he joined the Army ROTC
(which Admiral Train forgave only
because Princeton had no naval ROTC).
This step committed young Train to four
years of military service and from 1941 to
1945 he served on active duty in the U.S. and overseas, rising to the rank of major.
Influenced by the example of an uncle  - prominent New York federal judge
Augustus Hand - Train decided to attend Columbia University Law School after his
army discharge and earned an L.L.B. degree in 1948.

Russell Train devoted the first part of his career to government service as an
attorney and jurist. From 1948 to 1965 he served successively as legal advisor for
the Congressional Joint Committee of the House Ways and Means Committee
(where he became an expert on tax law); Chief Counsel, then Minority Advisor to
the same committee; and Assistant to the Secretary of the Treasury and chief of
the department's tax legislative staff. In 1957 President Dwight Eisenhower asked
the 37 year old lawyer to complete an unexpired term as U.S. Tax Court Judge,
following which President John F. Kennedy chose him for a full 12 year
appointment.

At this point, Train's path in life seemed clear. He could look forward to many
secure years on the bench, which was fortunate; in 1954 he had married Aileen
Bowdoin and now had small children to support. Despite these factors, he radically
changed the course of his career. Actually, the metamorphosis began some time
earlier, during two safaris to East Africa in 1956 and 1958. Observing the fragility of
the African wilderness in the face of encroachment, in 1959 Train founded the
Wildlife Leadership Foundation. Through it, he attempted to help the emerging
nations of Africa establish an  infrastructure of professional resource management
in order to establish effective wildlife parks and reserves. His foundation  continues
to offer expertise along these lines.

Train's final environmental awakening occurred in 1965. From 1959 until that date,
his involvement in conservation issues deepened  and he met many figures
associated with it internationally. But at age 45 he decided to abandon the safety of
the tax court and accepted an offer to be president of the non-profit Conservation
Foundation. A research, education, and information-oriented institution, during his
tenure it stressed citizen participation, supported demonstration projects which
infused ecological considerations into development planning, and sponsored a
major conference on environmentalism in international economic growth. Train also
focused the foundation on finding methods to insert greater environmental
awareness  into federal policy-making processes.
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EPA History - Russell E. Train: Oral History Interview                                    Page 3 of 18
                      After three years in private life, Train found himself drawn back to government. In
                      1968, President Lyndon Johnson appointed him to the seven-member National
                      Water Commission. With the election of Richard M. Nixon to the presidency in
                      November of that year, Train figured prominently in one of the many task forces
                      established by the new president to review all executive functions. Nixon asked him
                      to chair a group on resource and environmental issues, which he did between
                      November 1968 and January 1969. The subsequent report proposed a White
                      House office of environmental policy, an idea which bore fruit on January 1, 1970 in
                      the National Environmental Policy Act (NEPA). Meantime, President Nixon
                      appointed Train Undersecretary of the Interior. Here he led the Alaska Pipeline
                      Intergovernmental Task Force, a difficult job which took almost one year. But with
                      the passage of NEPA, the president established the Council on Environmental
                      Quality (CEQ) and named Train to be its first chairman.

                      Russell Train and his small White House staff quickly defined the environmental
                      role of the CEQ. They assumed the duties of advising the president on policy,
                      drafting legislation, coordinating all federal activities, and preparing an annual
                      report on the state of the nation's environment. Train also carved out important
                      international responsibilities for himself; for instance, becoming chairman of the
                      NATO Committee  on the Challenges of Modern Society.

                      No  sooner had the CEQ established its own mission than a second federal
                      environmental institution came into being. The Environmental Protection Agency
                      (EPA) opened its doors in December 1970  and its Administrator, William D.
                      Ruckelshaus, found himself following Train's recent example; that is, struggling to
                      define the role of the new agency. From the early stages, it became evident that
                      while  the two organizations would work closely together,  they would defer to each
                      other  in two spheres. Train and his staff would concentrate on policy formulation
                      and international environmental activity, while William Ruckelshaus and EPA would
                      focus  on implementation.

                      Clearly, however, by 1973 the main tenants of environmental policy had been laid
                      and EPA began to assume the dominant position. In April of that year, as the
                      Watergate Crisis rose in intensity, Ruckelshaus resigned from EPA to become
                      Acting FBI Director. Realizing the agency had become the "principal arena" for
                      environmental activities, Russell Train declared his interest in becoming EPA
                      Administrator and in May 1973 President Nixon nominated  him for the position. He
                      served as the second administrator from September 1973 to January 1977, during
                      which time the agency expanded its  interest in international affairs and turned to
                      risk assessment as an instrument of policy-making. More important, at a time when
                      the supply and cost of energy became paramount in the United States, Train  and
                      the EPA succeeded in "holding the environmental line."

                      Russell Train's personal commitment to conservation survived the rigors of eight full
                      years as a federal  environmental leader. In 1978 he was named president and chief
                      executive officer of the World Wildlife Fund (U.S.) and became its chairman of the
                      board in 1985.

                      Looking back on his service to the EPA, Russell Train  reflected on an intangible but
                      vital contribution of his tenure. He felt that his most important achievement involved

                            building the credibility of the agency....We didn't have any major
                            setbacks insofar as public confidence was concerned. We were able
                            to resolve political problems within the administration and the White
                            House in a way that did not diminish respect for the agency. We had
                            good Congressional relations....The  important thing we did was to
                            build the credibility of the agency with the public.
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EPA History - Russell E. Train: Oral History Interview                                   Page 4 of 18
                      Interview


                      Early life and influences

                      Q: Mr. Train, would you briefly describe your upbringing and early family life?

                      MR. TRAIN: I grew up here in Washington, D.C., which makes me a little unusual
                      in government. I was born in 1920, in Jamestown, Rhode Island. My father was a
                      Naval officer, and in those days, sea duty was largely on the East Coast. Our
                      principal home was in the District of Columbia where both my father and mother
                      had grown up, but in the summertime, the fleet went North to New England, I
                      suppose for a more salubrious climate than Norfolk, Virginia. During the summers,
                      my family took a house in Jamestown, an island just off Newport in Narragansett
                      Bay. That's where I happened to have been born, but the fact is that other than
                      that, my life has been here in Washington.

                      My two older brothers and I went to school here.  I went to the Potomac School and
                      then to St. Alban's, where I graduated in 1937. I went from there to Princeton
                      University, where my brothers had gone. I was in the class of 1941 and majored in
                      Political Science, or Politics as it was called at Princeton.  I joined the Army ROTC
                      since there was no Naval ROTC. My father finally accepted this. But, that meant
                      that on graduation, in June of 1941, I  went straight into the Army on active duty and
                      spent over four years in military service  here and overseas, ending up in Okinawa. I
                      came back in the spring of 1945.

                      Shortly thereafter, I entered Columbia Law School in New York and graduated from
                      there. In those days, following the war, there was a short course in which there
                      were no summer vacations, and so I went to law school for two years and
                      graduated in the class of 1948. Then  I came back to Washington and went to work.

                      Q: In the early years, can you recall any mentors at school or at  home? Any people
                      who influenced you greatly?

                      MR. TRAIN: Well, I think obviously our parents have a good deal of impact,
                      whether you know it or not at the time and whether you admit it or not at the time.
                      On the other hand, my father was  away from home a great deal, being a Naval
                      officer. There was a good deal of sea duty involved. I had an uncle who was a very
                      formative influence; a Federal judge named Augustus Hand. He  was married  to my
                      father's sister and was a judge of the  U.S. Second Circuit Court of Appeals in New
                      York, and one of the most distinguished judges on the Federal bench. He doubtless
                      influenced me to go into the law.


                      Career prior to EPA

                      Q: By what route did you arrive as Administrator of EPA?
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EPA History - Russell E. Train: Oral History Interview                                    Page 5 of 18
                      MR. TRAIN: By a devious one (laughing)! I was in public life in Washington from
                      the moment I got out of law school. I went directly from law school to work as an
                      attorney on the Congressional staff of the Joint Committee on Internal Revenue
                      Taxation. I remained in public service in various capacities until 1965 when I
                      resigned as a judge of the United States Tax Court to become president of the
                      Conservation Foundation. I spent approximately three years doing that until I  re-
                      entered government in the Nixon Administration as Undersecretary of the Interior,
                      beginning in 1969.

                      I guess that early on I became completely committed to public service of one  kind
                      or another; a career in government was quite a natural thing for me. However, I
                      didn't have very much exposure to environmental matters in the early part of my
                      government career.

                      To raise the political aspect, I was identified early as a Republican. However, we
                      didn't have any particular political identification at home. Certainly, my father didn't.
                      Being a Naval officer, he was completely non-political, although he had  been  a
                      Naval aide to President Herbert Hoover, so he had a loyalty there. I suppose  he
                      probably was a Republican.

                      Nonetheless, after I had been on the staff of the Joint Committee on Internal
                      Revenue for several years, I became Clerk of the Ways & Means Committee  for a
                      Republican Chairman, Daniel Reed of upstate New York. That was the last time to
                      this date that the Republican Party controlled the House of Representatives. So, I
                      was identified as a Republican up to that point, although in those days politics in
                      the District of Columbia had not become as active as they are today.

                      In any event, I went on from there to the Treasury Department during the
                      Eisenhower Administration. I worked for Secretary of the Treasury George
                      Humphrey as head of the Legal Advisory Staff, which essentially handled all tax
                      legislation and regulatory matters.  From there, I was appointed by President
                      Eisenhower to fill the unexpired term of a U.S. Tax Court Judge who had died in
                      office. Then, I was re-appointed to a full term by President Kennedy. As I recall, I
                      went on the Court in 1957 or 1958 and resigned in 1965.

                      During that period, I had gone to Africa on a couple of private trips and on a few
                      safaris and became very interested in African conservation. In my spare time, in
                      1960 or 1961 I started an organization called the African Wildlife Leadership
                      Foundation which still exists here in Washington  and has an office in Nairobi. It is
                      one of the principal international organizations involved with conservation in Africa.
                      That got me involved with environmental matters, with conservation issues, and
                      with the people involved in the movement.

                      Then, in 1965 I agreed to leave the Tax Court and become President of the
                      Conservation Foundation. After I became President, the principal thrust of the
                      Foundation was to develop ways in which environmental values and environmental
                      considerations could be brought into the decision-making and policy-making
                      processes.

                      About 1967, the Senate Interior Committee, then chaired by Senator Henry "Scoop"
                      Jackson of Washington, was considering environmental issues and how to build
                      environmental considerations into government decision-making. At the
                      Conservation Foundation we had a small advisory board, one of whose members
                      was Professor Lynton "Keith" Caldwell,  a political scientist at the University of
                      Indiana, who had been giving a good deal of thought to these issues. The staff of
                      the Senate Interior Committee asked whether the Foundation could finance a
                      consultancy for Professor Caldwell to work with the committee on these issues. We
                      did, and he did, and he became the principal architect of the Environmental Impact
                      Statement (EIS), as well as the National Environmental Policy Act (NEPA). So, we
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EPA History - Russell E. Train: Oral History Interview                                    Page 6 of 18
                      at the Foundation worked very hard and were personally involved in the labors that
                      eventuated as NEPA. I don't think this is a story and an association that has been
                      particularly well-known.

                      Toward the end of 1968, following the election of Richard Nixon,  I was asked to
                      chair a task force on environmental issues. President-elect Nixon had a very
                      extensive task force mechanism that was put together by Dr. Paul McCracken, who
                      later became Chairman of the Council of Economic Advisors in the Nixon White
                      House. McCracken's executive assistant, a man by the name of Henry Loomis, had
                      been head of the Voice of America, and I believe, Commissioner of Education.
                      Loomis also happened to be associated with the Conservation Foundation. He was
                      a close personal friend of mine, as well as director and treasurer of the Foundation.
                      So, Henry called me up after the election (he was already working for McCracken)
                      and said, "We're setting up task forces on just about every conceivable issue; from
                      taxation to space exploration, from public health and education, to defense. Don't
                      you think we should have a task force on the environment? If we do, would you
                      chair it?"

                      My answer was, "Yes," on both scores; "yes" to the task force, and "yes," I would
                      chair it. I put together a totally bipartisan task force of around 15 to 20 people.
                      Incidentally, I never had the slightest suggestion from the in-coming Nixon
                      Administration as to whom I should appoint to the group. In any event, we came up
                      with a rather short report whose principal proposal was the establishment of a focal
                      point for environmental policy-making in the White House. We did not give a name
                      to it, but eventually it became the Council on Environmental Quality (CEQ).

                      Following our report, in the beginning of 1969, I was asked to come into the Nixon
                      Administration as Undersecretary of the Interior. I was an identifiable Republican
                      who already had some distinction in public office and who was considered to be a
                      conservationist; the term "environmentalist" was not yet in common usage at that
                      time. In any event, I became Undersecretary of the Interior at the very beginning of
                      the Nixon Administration. Walter Hickel was Secretary. Unfortunately, Hickel and I
                      had a fairly rough association for the next year, which had an impact on later
                      events.

                      Meanwhile, the National Environmental Policy Act was under consideration by the
                      Senate Interior Committee. I  was the Administration spokesman and testified
                      against the establishment of the Council on Environmental Quality, even though
                      after the election we had recommended it in the task force report. I took this
                      position because the President had established another agency,  a  Committee on
                      Environmental Quality chaired by Dr. Lee DuBridge, his science advisor. It was
                      made up of the various agency heads who had major interests in the environment,
                      like the Secretary of the Interior, the Secretary of Agriculture, and so forth. It
                      represented the White  House's initial response to our task force report, and while it
                      was a starter, like most inter-agency committees it wasn't terribly effective. It tended
                      to represent what I would call the lowest common denominator among the existing
                      agencies, rehashing what they were doing already or wanted to do in the future.
                      There was no new cutting edge there.

                      While I testified against some aspects of NEPA in the Senate, by the time the bill
                      was under consideration in the House (before John Dingell's Subcommittee of the
                      Committee on Merchant Marine and Fisheries) we managed to turn the
                      Administration around and I was able to support the legislation. When the NEPA
                      was passed at the end of 1969, I suggested to the White House that I be appointed
                      the first Chairman of CEQ. Given my increasing difficulty with Secretary Hickel (and
                      to be fair, his increasing difficulty with me), that seemed like a good arrangement all
                      around. The White House bought it, and I did become the first Chairman of CEQ  in
                      early 1970. Nixon signed  the National Environmental Policy Act on January 1, 1970
                      as his first official act of the decade and I remained at CEQ until I went to EPA in
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EPA History - Russell E. Train: Oral History Interview                                    Page 7 of 18
                      September 1973.

                      Of course, CEQ began a year before EPA came into existence. EPA resulted from
                      a recommendation by a presidential commission on government reorganization,
                      known familiarly in those days as the Ash Council. It was chaired by Roy Ash who
                      later became the first Director of the Office of Management and Budget (OMB).
                      There was a good deal of debate within the Administration about an organizational
                      home for environmental concerns; not about whether there should be some new
                      institutional arrangement in the government to deal with the environment, but just
                      exactly what that institution should look like, where it should be located, and how it
                      should be organized. I think the White House leaned towards establishing a major
                      new Department of Natural Resources and the Environment. I am not quite clear as
                      to how it was to be put together. Of course, talk of a Department of Natural
                      Resources has persisted ever since.

                      By the time I testified before the Ash Council, I  had reached the conclusion that it
                      was much better to start off with a clearly defined,  independent agency with a
                      clearly defined mission than have an environmental structure tied to a much bigger
                      natural resources organization. There it would be subject to bureaucratic
                      entanglements, a loss of identity, and a fuzziness of mission. I said at the time that
                      what we needed - and what the public wanted - was an organization with a clearly
                      defined mission: to be the sharp, cutting edge of environmental policy in the
                      government, and at the same time be clearly identifiable and understood by the
                      public. I like to think that I had something to do with moving the decision in that
                      direction. Today, of course, the effort is being made to make EPA a department,
                      which I think it should be. But at that time (1970) I think we  reached the right
                      answer.

                      So, EPA came into existence on December 2, 1970 as a result of Reorganization
                      Plan Number 3. The  National Oceanic and Atmospheric Agency (NOAA) came into
                      being at the same time under Reorganization Plan Number 4. As Chairman of
                      CEQ, I was the principal Administration witness - one might say lobbyist - for these
                      reorganization plans on the Hill. I visited all the various committee chairmen whose
                      jurisdictions were going to be affected, ranging from Agriculture, to the Joint
                      Committee on Atomic Energy, to the Interior, to Public Works, and all the rest.
                      Finally, the reorganization  plans went through,  and EPA came into  existence.

                      CEQ then continued on its own course. We saw ourselves in those days as the
                      principal policy development arm of federal environmentalism, while EPA was the
                      principal implementing, regulating, and enforcing arm. During the next three years,
                      CEQ was responsible for bringing together an enormous range of new policy
                      recommendations to the President and the Congress, relating to clean air and
                      water, toxic substances, safe drinking water, surface mining, endangered species,
                      and other areas. There was an extraordinary outpouring of public and political
                      response to the environmental crisis, a sense that we were coming to grips with a
                      major problem in our national life. I think that in those years, the legislative and
                      regulatory responses and the Executive Orders relating to the environment
                      represented the most comprehensive set of initiatives produced in any domestic
                      area in the history of the country.

                      In any event, we worked very closely with EPA all through that time, and the more
                      EPA matured, the more it became the principal environmental player. By 1973 or
                      so, it was pretty hard to find any policy  initiatives to suggest to the President that
                      hadn't already been  put forward. There were some initiatives we recommended that
                      were never acted on, such as the National Land Use Policy Act. But I think it is fair
                      to say that by  1973, the action had pretty well begun to switch from CEQ to EPA,
                      which was quite natural. Then, of course, the Nixon Administration  - particularly
                      President Nixon himself- ran into the Watergate fiasco. Bill Ruckelshaus, the first
                      Administrator of EPA, left the Agency in May 1973 to become head of the FBI. He
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EPA History - Russell E. Train: Oral History Interview                                   Page 8 of 18
                      then became Deputy Attorney General under Elliott Richardson.

                      That is where I came in. Following Bill's departure from the EPA, which was pretty
                      sudden, I  began to give some thought to my own position and decided that I would
                      like a shot at the EPA Administrator's job. As I have said, by this time (1973) the
                      emphasis was less and less on the development of new policy and more and more
                      on making things work; implementing programs that had been  put into place and
                      enforcing  them. Clearly, EPA seemed to be the principal arena for all such
                      environmental activities.

                      To promote  my candidacy, I talked to some of the members of Congress with
                      whom I had  developed close working relationships. Certainly, I also talked with
                      people in  the White House. I remember at least one conversation with Alexander
                      Haig, who by that time was Chief of Staff, having taken Haldeman's place. There
                      were not many other candidates. One was John Quarles who became Deputy
                      Administrator with me. I think Henry Diamond was a candidate.

                      At any rate,  the White House, in its mysterious way, decided to give me the nod,
                      and I was nominated later that same spring, in May 1973. My confirmation hearing
                      was held in  June 1973 by the Senate Public Works Committee (which, at that time,
                      hadn't added "environment" to its title). But Senators Scott of Virginia and Hanson
                      of Wyoming put a hold on my nomination, and it remained in limbo until  September,
                      when the  objections were removed, and I was confirmed, either unanimously or
                      with one or two votes dissenting.

                      I then became the second Administrator, sworn in that month by Elliott Richardson.
                      I had originally asked President Nixon if he would swear me in. He and I had a
                      conversation about the job in the Oval Office about this same time. I  assumed it
                      probably would be  a politically shrewd thing for  me to be sworn in at  EPA by the
                      President. President Nixon was quite a  bit shrewder politically than I. He was in the
                      middle of  Watergate at that time, and said something  like, "that could probably be
                      just about the worst thing I could do for you." He was  always extremely pragmatic
                      about himself and his own value in  politics (although I must say other events would
                      not necessarily bear out the statement I just made). In any case, I was not sworn in
                      by him, but by my friend Elliott Richardson. His  Deputy Attorney General, Bill
                      Ruckelshaus, stood with us. Of course,  both Richardson and Ruckelshaus fell
                      victim to the "Saturday Night Massacre" not  long after that. Anyway, that's the
                      devious route whereby I got to head the EPA.


                      Nixon's  involvement

                      Q: You mentioned  President Nixon and a conversation in the Oval Office. Before
                      you became EPA Administrator, did he give you any advice - either written or
                      spoken - on your new job?

                      MR. TRAIN: I don't really remember him doing so. I would imagine that  President
                      Nixon was pretty preoccupied at that time with his various problems. I don't really
                      recall that he gave  me  any particular instructions. Now, Al Haig, as I  recall, went out
                      of his way to emphasize that I should recognize that there has  to be balance in
                      these jobs. I replied that I understood. I  suspect Haig  may have gotten that thought
                      from the President; I know Haig did not  have any personal association with the
                      environment whatsoever. The only thing I recall clearly was my conversation with
                      Nixon about the swearing-in.


                      Train's allies

                      Q: Mr. Train, were  you assisted by  any  particular environmental advisors, either
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EPA History - Russell E. Train: Oral History Interview                                    Page 9 of 18
                      inside or outside EPA?

                      MR. TRAIN: I don't really think there were any of major importance. There certainly
                      wasn't anybody on the outside that I  regularly looked to for environmental guidance.
                      There were people I had known in the scientific area such as Starker Leopold, a
                      zoologist at the University of California at Berkeley and the son of Aldo Leopold. I
                      probably had more contact with him when I was at the Interior Department than
                      after I went to EPA. Stanley Cain, a professor at the University of Michigan and
                      Assistant Secretary of the Interior, was another source. I mentioned Keith Caldwell
                      earlier. Ian McHarg, a landscape architect at the University of Pennsylvania, was
                      another one. There were  many contacts of this sort, but I  certainly wouldn't think of
                      them as mentors. That sounds a little self-important,  but the fact is, in the early
                      days, EPA was pretty much out front in environmental affairs. It was unlike the
                      situation today, where there is a wide body of people with experience and wisdom
                      in the environmental area. In those days, I won't say  CEQ and EPA stood alone;
                      but we were definitely out front.

                      I should qualify this by saying that as EPA Administrator, you get so busy you don't
                      really have  much time to talk to eminent people. You are moving from one issue to
                      another and flying by the  seat of your pants half the time.

                      Q: Did you  have advisors inside the government?

                      MR. TRAIN: At Interior, CEQ, and EPA, there were a fair number of associates
                      who were important. I think one of the most important associations was with  Al Aim.
                      He first joined my staff when I was Undersecretary of the  Interior, just before I went
                      to  CEQ. He became Chief of Staff for me at CEQ and then went to EPA as
                      Assistant Administrator for Planning  and Management. I would say he was by far
                      my foremost personal advisor and associate during my time at EPA.

                      At the White House, I  didn't have mentors, but John Ehrlichman was an important
                      force during my time at Interior and at CEQ, before he ran into problems during the
                      Watergate debacle. Mainly,  he was an  important force in gaining the President's
                      attention to environmental matters. Although John has come in for a lot of criticism,
                      give him credit for that. He was extremely important to me when I was
                      Undersecretary of the Interior. Thanks to him, we won some important
                      environmental battles before the enactment of NEPA.

                      For example, we prevented  the construction of a big  new international airport in
                      Dade County, Florida. It would have  been as large as Miami Airport, but we
                      determined it would have been destructive to the hydrology of South Florida, to the
                      Everglades, and so forth. The White  House came down on our side on that issue,
                      against all of the development interests in the Department of Transportation. Credit
                      for this basically goes to John Ehrlichman; his support was crucial. Later on, he
                      helped with the Alaska Pipeline question. This issue was assigned to my office at
                      Interior, and we had to grapple with it all through 1969, before there was any
                      National Environmental Policy Act or any Environmental Impact Statement process.
                      We had to  put together all of our own procedures for dealing with a complex set of
                      actions having substantial environmental impacts. Again,  Ehrlichman was
                      extremely supportive and helpful all through this debate.

                      Among people outside CEQ, I worked most closely with John Whittaker,
                      Ehrlichman's Principal Deputy on the Domestic Council staff. He was my principal
                      line of communication with the White House. I dealt with him on a daily basis,
                      whereas I would deal  with Ehrlichman - especially during the latter period - every
                      couple of months. I  communicated with the President perhaps twice a year. So,
                      John Whittaker was an important force. By the time I went to EPA, I think he had
                      become Undersecretary of the Interior, so our associations became less frequent.
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EPA History - Russell E. Train: Oral History Interview                                  Page 10 of 18




                      First impressions of EPA

                      Q: Did the EPA job surprise you in some ways?

                      MR. TRAIN: That's hard to answer. I knew it was a tough job before I went there
                      because I had seen a good deal of it. I guess I was surprised by the technical
                      nature of what I had to deal with. I  hadn't really had to grapple with technology
                      before. As an Administrator, you really find yourself getting into the most incredible
                      minutia, dealing with catalytic converters, or dealing with the possible de-
                      registration of a pesticide. These were decisions an Administrator had to make  by
                      law, frequently with legal findings. That was certainly new to me.

                      But, I guess there wasn't an awful lot that took me by surprise. I had been around
                      the environmental track for about three years by that time, and I knew most of the
                      players and most of the problems.  What I found at EPA was very much what I
                      expected. However, it was a much bigger bureaucracy than I had ever had to deal
                      with before. Even by 1973, EPA had by no means sorted out its inter-program
                      conflicts. We all know Ruckelshaus had to struggle with that a great deal, bringing
                      the various groups together from HEW and Interior and so forth. The Assistant
                      Administrators were still fighting  over what floor their offices should be on. I think by
                      the time I got there, nothing much had changed in that regard (laughing). I don't
                      think there were any great surprises.

                      I certainly learned that at EPA you  are in the middle of controversy all the time.  I
                      probably was not accustomed to the amount of media attention I received on just
                      about  everything. That was something new to me. Of course, I found myself
                      embroiled in all the inter-agency struggles, as well as with the White House and
                      with OMB. I had felt some of it at CEQ and Interior, but it was more pronounced at
                      EPA. It was the nature of the beast.


                      Main policies

                      Q: Could you outline the half-dozen most important policy questions you faced  as
                      EPA Administrator?

                      MR. TRAIN: Let me start with this anecdote. When the auto emissions controversy
                      resulted in some very, very important public hearings, I was called upon to preside
                      over them. We  had to use the Department of Commerce auditorium, it received so
                      much  attendance and interest. The principal problem was whether or not to
                      approve the catalytic converter. In the Clean Air Act, Congress had mandated a 90
                      percent reduction for auto emissions, leaving it up to the manufacturers to decide
                      how in the world they were going to comply. It also gave the Administrator a certain
                      leeway in terms of providing some  extensions of time. As I remember, the industry
                      devised the catalytic converter as its way of trying to achieve the mandated
                      reduction. The converter was supported by the Mobile Source Office of EPA, but it
                      was very much opposed by a number of the health scientists in the Agency.

                      So I had two elements of the Agency pitted against each other. The Mobile Source
                      people were basically engineers, and the other side of the coin was represented by
                      the health scientists. The latter group argued that catalytic converters would emit a
                      fine aerosol of sulfuric acid, so that anyone standing alongside a Los Angeles
                      Freeway would essentially be inhaling a sulfuric acid mist, which was extremely
                      damaging to health. This was a very tough decision to make. I came down on the
                      side of the catalytic converter, which, in hindsight, seems to have been the right
                      decision. I like to think it was some great wisdom on my part, but I can't remember
                      any great wisdom.  In any event,  it was a very tough decision. At one point, I did
                      give the auto industry some additional time to meet the 90 percent reduction.
                      Predictably, I caught all sorts of hell from the environmental community.
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EPA History - Russell E. Train: Oral History Interview                                  Page 11 of 18
                      The registration and de-registration of pesticides and herbicides was also a big
                      question. Ruckelshaus had already dealt with DDT. But when I came in, I had on
                      my desk the problem of permitting the emergency use of DDT in the forests of the
                      Northwest to control the tussock moth. At that time, the moth was in the third or
                      fourth year of a population explosion which threatened to decimate the timber
                      forests of the Northwest. Everyone - including three governors, six senators, and
                      every House delegation from the Pacific Northwest - urged me to permit the use of
                      DDT on an emergency basis.  I could allow it under the statute banning DDT, which
                      I finally did. When I  went to Seattle to make the announcement, the room was filled
                      with environmentalists, a number of whom were weeping over the decision. Maybe
                      that was not the toughest decision, but it was one of the most emotional ones I had
                      to deal with. It was not only very hard, it occurred as soon  as I walked into the
                      office. I should add  that after using DDT on the tussock moth, the population did
                      collapse;  but it might well have collapsed anyway. It was tough.

                      On the broader question of pesticides and cancer, Ruckelshaus had previously
                      decided to ban DDT. I had to deal with aldrin, dieldrin, heptachlor, chlordane, and
                      some others as well. These, too, were very difficult issues  and  created an
                      enormous amount of flak within the agricultural community, particularly in the
                      Agriculture Committees of the House and Senate, where I  always  had the toughest
                      time. In the House Agriculture Committee, the number two ranking Democrat was
                      Congressman Tom  Foley from the State of Washington, now the House Speaker.
                      Although  he had a strong agricultural constituency, Tom was always fair and
                      decent and helpful whenever I testified. Hardly anybody else was so considerate
                      (laughing). I was a political football. But we did make the tough decisions on the
                      persistent pesticides. I appointed a Committee on Cancer  Policy which I think was
                      influential in helping to develop guidelines that are still in use today.

                      Toxic substances control absorbed much of my time at EPA. I began work on toxic
                      substances legislation when I  was still with the Department of the Interior. I had
                      already been named Chairman of CEQ, but we had no office yet, so three or four of
                      us used my office at Interior and started working on toxic substances. At that time,
                      there was a big mercury scare in swordfish, which led us to conclude that rather
                      than reacting to each specific chemical scare, we needed  a more generic
                      approach. It led finally to the Toxic Substances Control Act, which was developed
                      at CEQ. Terry Davies did most of the work, and it was still  being debated when I
                      became EPA Administrator. We worked hard to get it enacted into law, and finally
                      succeeded.

                      The "significant deterioration issue" in the Clean Air Act was also a hard fight. We
                      ultimately got the Congress to rule on the side of the best available technology -
                      scrubbers, principally - rather than relying on tall stacks. Until Congress acted, it
                      was a big struggle.  Sometime during the Ford Administration -  probably 1974 or
                      1975 - some of the  White House staff who worked with Congress attempted to
                      eliminate  those provisions of the Clean Air Act which prohibited "significant
                      deterioration" of air  quality standards. They encouraged some of the conservative
                      members of the Senate to promote legislation along that line. In fact, legislation
                      was actually introduced and referred to the Public Works Committee! I thought this
                      was very  dirty pool;  these White House staffers were working behind my back and
                      around the Agency  and not even consulting the appropriate members of the
                      Senate. It became a big problem for me. I went to Howard Baker, the ranking
                      Republican on the Senate Public Works Committee, and he was properly outraged
                      by this whole process, as indeed were all the Republican minority  members of the
                      committee. We scheduled a meeting with the President in  the Cabinet Room of the
                      White House. Every single one of the Republican minority  members attended. I
                      can't recall all of them, but they included Howard Baker, James Buckley, Pete
                      Domenici, and Jim McClure. To a man, they  laid down the law to the President on
                      this question, saying such  interference was unacceptable.  The White House then
                      withdrew  its offensive, and that was the end of that.
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EPA History - Russell E. Train: Oral History Interview                                  Page 12 of 18
                      Certainly, the relationship between energy and the environment became an
                      enormously important issue in the wake of the Arab oil embargoes. As you
                      remember, the President appointed a series of energy czars, starting with the
                      former Governor of Colorado, John Love; followed by Bill Simon, later the Secretary
                      of the Treasury; followed by Frank Zarb; followed  by John Sawhill. The energy
                      versus environment debate became the principal arena for action during my last
                      year or so at EPA. In fact, during both the Nixon Administration and the Ford
                      Administration - during my entire time at EPA - this issue was joined. Nixon got very
                      much involved on the energy side of the controversy before he left office. By then,
                      the bloom was off the environmental rose and the name of the game was to
                      promote energy supply. This was the Administration's viewpoint.  So, almost
                      everything was looked upon from the standpoint of whether it promoted or depleted
                      the nation's energy supply. The fight over sulphur standards and emissions reflects
                      this emphasis on  energy. But even though we had some tough, tough fights, we
                      never lost a major battle, and not many small ones either. There was a good deal of
                      rhetoric;  a lot of Congressional hearings and meetings at the White House. But by
                      and large we were able to hold the line on all of the environmental legislation and
                      regulations. I think this was a major accomplishment because all the political
                      strength  was really on the energy side.

                      A major factor we had going for us was good economic analysis. One of the most
                      important things Al Aim did for us was to build a strong economic analysis
                      capability. I think we had about the best in the government (although I also think it's
                      declined since those days). As a result, when I would go into a meeting at the
                      White House on auto emissions or other subjects, we always had better economic
                      data than the other side. We even did better than the Department of Commerce. I
                      always thought this fact was extremely influential in our successes.


                      Relations with Congress

                      Q: You alluded to your relations with Congress. How would you characterize the
                      overall relationship?

                      MR. TRAIN: Overall, I would say very positive. This is a very important point to
                      make because I think the climate has changed a lot in that regard. In my day,
                      EPA's principal association in the Senate was the Public Works Committee.
                      Senator  Ed Muskie was the number two Democrat on it, and the  principal  mover in
                      air and water legislation. Much of what he eventually came to support was shaped
                      by the recommendations of the Nixon and Ford Administrations, although  he
                      opposed much of what we tried to do in the early days. The chairman of that
                      committee was Senator Jennings Randolph of West Virginia, with whom I  always
                      had a good relationship. He was an old-style politician, more interested in public
                      works than the environment. He  pretty well left Muskie to run the environment on
                      the Democratic side. I always had a good relationship with Muskie, although it had
                      its ups and downs. Ed was a very mercurial individual, tended to lose his temper
                      quite quickly and  recover it equally quickly. Ed had a very active and aggressive
                      staffer on environmental matters named Leon Billings. Leon didn't let many days go
                      by without calling  and telling you what you did wrong. But these relationships were
                      manageable.

                      On the Republican side, I  received remarkable support. Give Senator Howard
                      Baker a lot of credit for that. Howard was highly respected by the less senior
                      members of the committee, was  always extremely helpful to me,  and worked well
                      with Muskie and with Jennings Randolph. I always had good support from
                      Republicans in dealing with the White House, especially from Senator Jim Buckley,
                      the head of the Environmental Subcommittee on the Public Works Committee.
                      Although very conservative, Buckley happened to be an old personal friend, and we
                      had an excellent relationship. Jim became a strong ally when EPA opposed the
                      new Supersonic Transport (SST) aircraft. (The Agency recommended reduced
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EPA History - Russell E. Train: Oral History Interview                                  Page 13 of 18
                      appropriations and tough permits). Of course, Buckley opposed the SST because
                      he thought it was uneconomical, while we opposed it because we were worried
                      about the ozone layer and other environmental problems. I would say generally that
                      in those years the legislative product of the Public Works Committee was really a
                      bipartisan effort.

                      The relationships on the House side were more complicated. There were more
                      committees and subcommittees involved, and the relationships were more
                      politicized. But by then I had known many members of the House for some time.
                      For instance, I had quite a good relationship with John Dingell. I had also known
                      Paul  Rogers for a long time. In fact, Rogers' father had been on the Ways & Means
                      Committee when I was on the staff, as had Dingell's father. So we had long
                      associations, and generally speaking, the Agency had good Congressional
                      relationships.

                      The House Appropriations Committee was a special case. The present Chairman
                      of Appropriations, Jamie Whitten, was then Chairman of the Subcommittee which
                      dealt with CEQ and EPA. Jamie was difficult. He and I got along very well
                      personally, had a good relationship,  and trusted each other. But I learned that when
                      I made a decision on something like an agricultural pesticide - something that was
                      going to make Jamie really unhappy - the best thing to do was to let him know just
                      a little bit in  advance so he wasn't taken by surprise. As long as Jamie wasn't taken
                      by surprise, we got along fine;  but he could be very difficult on environmental
                      issues. Generally, he was certainly not pro-environment. Ed Boland, a Democrat,
                      became Chairman  of that Subcommittee later on, and it became an entirely
                      different situation. Boland was from Massachusetts and was an extraordinarily able
                      and even-handed Appropriations Subcommittee chairman. He ruled that
                      subcommittee, but  he had a good staff, and you always got a very fair shake from
                      Ed. I  don't recall the other members  now, but Ed Boland was absolutely first rate.

                      Again, I would generalize that our Congressional associations were very good, very
                      supportive. Obviously, some individual members behaved in a manner which drove
                      me right up  the wall. These were the  ones who hauled me up to Capitol Hill and
                      beat  me over the head, either publicly or privately. But that's part of the process.
                      You expect  that. Overall, I think we had extremely good support.


                      Contrast between  Nixon  and Ford

                      Q: Could you contrast the environmental views of President Nixon with those of
                      President Ford?

                      MR. TRAIN: Nixon made a decision early in his Administration that the environment
                      was important politically. He was supported and encouraged in that view by John
                      Ehrlichman. I have no doubt about this whatsoever.  I can illustrate with an incident
                      which happened about January 1969. It happened in New York, before Nixon was
                      inaugurated, when  his transition office was at the Pierre Hotel. I mentioned earlier
                      that I had chaired a task force on the environment for the President-elect. As
                      thanks, he gave a dinner at the Pierre Hotel early in  January of 1969 for all of his
                      task forces. There were a lot of people; many of these task forces had 15 to 20 on
                      them, and there must have been at least 20 such  panels altogether. In fact, we
                      filled  the Grand Ballroom of the hotel. Nixon invited the various chairmen and
                      chairwomen to sit at the head table with him, up on a platform. By the luck of the
                      draw, I was  seated on his left. I had discovered I was going to sit next to him about
                      two hours before the dinner.

                      When I finally got his attention  - diverting it from the  guy on his other side who
                      headed the  Space  Exploration Subcommittee and was spinning visions of
                      moonshots and space probes -1 knew I had a lot to  compete with. When Nixon
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EPA History - Russell E. Train: Oral History Interview                                   Page 14 of 18
                      turned to me, I said, "I learned about two hours ago that I was going to be sitting
                      next to you at dinner. I've spent the last two hours thinking this may be the only
                      opportunity I will have to get a message across to the next President of the United
                      States. I asked myself what I  should talk about, what I should say; it seemed
                      terrible to approach a dinner conversation in this way." Nixon said, "Not at all.
                      That's exactly the way you should have approached it." Then he said, "What was
                      your conclusion? What did you decide to tell me?" I  said, "I decided to talk to you
                      about the politics of the environment, why I feel it is  politically important."

                      I had his immediate attention, and he listened to me without interrupting. He was an
                      unusual politician in that regard. He would actually listen - at least at that time.
                      Later on, as a defensive measure, he tended to talk a lot. In any case, I talked to
                      him about the importance of the environment, a concern which involved every
                      geographic region of the country, which involved all  kinds of people and interests,
                      and which could be used to help unify the nation and bring people together. He
                      nodded his head and indicated that he understood.  He said, "that sounds pretty
                      good. But, what about the poor and the blacks living in the inner cities?" Of course,
                      he had instantly put his finger on an  extremely important aspect of what I had been
                      saying, one which was very often overlooked, and is still overlooked. So I
                      discussed the relationship between poverty and the environment with him, about
                      lead paint, about the fact that people in the cities suffered more from air pollution
                      than others.

                      I tell this story to underline the fact that from the beginning, Nixon had a keen
                      appreciation of the political importance of the environment. I think it clearly
                      influenced the first three years of the Nixon Administration. It certainly was a great
                      help to us in achieving our agenda at CEQ.  President Nixon issued an annual
                      environmental message  to the Congress, and to this day I am absolutely amazed at
                      what we got away with! Absolutely amazed! At the same time, Nixon ran a tough
                      White House, due to people like Ehrlichman and Haldeman. They were tough
                      operators and ran a very disciplined ship; a taut ship, in Navy parlance. Also, a very
                      political ship. But that was a side I saw little  of.

                      President Ford, on the other hand, was a much more relaxed human being than
                      Nixon. He was not a driven man in any sense at all. He became President of the
                      United States more by happenstance than anything else, and the people he
                      brought in reflected that. It was a much more relaxed White House, much more
                      tolerant of a diversity of viewpoints within the Administration. I always had a feeling
                      with  Ford that if I really needed to take something to the President, I could. More
                      than that, he probably would come down on my side. I felt I had that sort of
                      relationship with him. With  Nixon, it was a much tenser sort of a situation. But they
                      were a tense crowd; all of them! (laughing)


                      EPA and industries

                      Q: How would you  characterize your relationship with the industries you were
                      asked to regulate as EPA Administrator?

                      MR. TRAIN: It was pretty hard going. The agricultural industry, for instance, was
                      always very difficult to deal with, and almost always opposed pesticide regulations.
                      They also had very vocal allies on Capitol Hill, which made life difficult.

                      Manufacturing industries were a good deal more difficult in those days than today.
                      Even then, attitudes within industry were evolving; but since that time there has
                      been a generational change. Younger people who are more accustomed to
                      environmental issues and values have assumed positions of responsibility.  But in
                      my time we had some awfully tough  struggles with the steel industry, particularly
                      U.S. Steel (now called U.S.X.). They fought us tooth and nail over coke oven
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EPA History - Russell E. Train: Oral History Interview                                   Page 15 of 18
                      emissions, fugitive emissions, all those things. They had more lawyers than we did.
                      It was hard. They had plants in so many locations, it was very difficult for us to fight
                      them on all fronts. I eventually closed down U.S. Steel in Birmingham; we actually
                      shut down their ovens. It came to that kind of head-on collision.

                      The chemical industry was very divided over the Toxic Substances Control Act. But
                      I will say that from our point of view, there was considerable leadership shown by
                      the DuPont Company. Again, I would say relationships were often strained, but
                      they were evolving. They were changing. I think more and more, industry was
                      seeing that they had to do these things.

                      The auto industry always fought tooth and nail against any additional standards,
                      either on emissions or fuel efficiency. I don't ever remember the auto industry or
                      any related manufacturers saying, "That's something we could do." It was always,
                      "We can't do it."


                      EPA, the states,  and the cities

                      Q: How was your relationship with the states  and municipalities?

                      MR. TRAIN: I am tempted to say, like every other relationship that EPA had, very
                      edgy (laughing), very controversial. It is difficult to typify. In the Office of the
                      Administrator, we worked hard to maintain good working relationships with the
                      states and with the mayors. We met with them quite a lot. We were, of course, in
                      the process of handing over a good deal of authority to a lot of the states, including
                      permit authority under the Water Pollution Program. Money was always an issue.
                      We used to have a small grants program to assist the states in their administration
                      of environmental laws, which OMB always tried to cut back. They usually
                      succeeded in getting rid of most of it.

                      During my time at EPA, I think an important development in our state and local
                      relationships was the Sewage Waste Treatment Construction Grant Program,
                      which we got going with full force. When I came in, the Sewage Treatment Program
                      was probably operating on something like $200 million a year; it was something like
                      three or four billion dollars  by the time I left. It became a huge, huge program with
                      all sorts of Congressional interest, and a lot of money falling to the states and local
                      communities. It therefore became a very important element in the federal-state
                      relationship.

                      Another, more abrasive question involved some of the transportation control plans
                      proposed under the Clean  Air Act. We ran into situations like Los Angeles, where
                      the EPA was ordered by a Federal Court in California to impose commuting
                      restrictions (such as carpools and prohibitions on driving during certain days of the
                      week). It was an effort to bring the ambient air quality to acceptable norms in the
                      Los Angeles Basin. Of course, there was no way to comply, short of calling out the
                      National Guard. I suspect some legal decisions of this kind probably involved
                      sweetheart cases cooked up between our more evangelical air people and a couple
                      of the public interest law firms. Nonetheless, we tried to institute quite a number of
                      transportation plans around the country, most more modest than the one I
                      described for Los Angeles. But they tended to be controversial. Our efforts ceased
                      after a member of the House Appropriations Committee added a provision to the
                      Clean Air Act, saying that no monies appropriated under its titles could be used to
                      implement any transportation plans. This marked the end of that program. It had
                      involved us in all parts of the country, connected us with  many mayors and
                      governors, and encouraged an awful lot of interaction with the states.


                      EPA and the environmental movement
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EPA History - Russell E. Train: Oral History Interview                                  Page 16 of 18
                      Q: How would you characterize EPA relations with the environmental movement?

                      MR. TRAIN: Just about as difficult as industry! (laughing) When I first joined EPA I
                      decided to have regular meetings with the heads of the principal environmental
                      organizations. They were held about once a month. The leaders of these
                      organizations came to the first meeting, but by the second meeting they had
                      passed on this responsibility to the young staffers in their Washington offices.
                      Pretty soon, it seemed all I did was call these meetings and have these young
                      Turks tell me what a jerk I  was and what a poor job I was doing; how I was
                      crucifying  the environment and selling out to industry, and so forth. It finally seemed
                      to me a totally unproductive exchange, and I didn't call any more meetings. I never
                      said we weren't going to have any more sessions;  I just never called any more. Life
                      was too short, and I had only a certain reservoir of energy and blood. I thought
                      there were more  important battles to fight than those with the environmental
                      community.

                      Having said that, when push came to shove, my relationship with the environmental
                      community was pretty good. But almost every issue that was hot then is still hot
                      today. The Administrator of EPA cannot very often make a decision that is going to
                      completely please the environmental community. These decisions usually run  down
                      the middle, and flak tends to come from all sides. It's the nature of the operation.


                      EPA in the international setting

                      Q: Were there heavy  demands on you in the international arena?

                      MR. TRAIN: Yes, there were demands on me, but that was probably because I was
                      more interested in it than were others. I had been involved with many of the
                      initiatives when I  was at CEQ. When he was Administrator for the first time and I
                      was at CEQ, Bill  Ruckelshaus agreed to let CEQ handle most of the international
                      activities. This kept the two of us from developing bureaucratic problems.  In any
                      event, at CEQ I had been the President's representative to the NATO Committee
                      on the Challenges of a Modern Society (CCMS). CEQ had also written the
                      environmental agreement with the USSR that Nixon signed at his first summit
                      meeting in Moscow in June 1972. The Soviet agreement was  an extremely active
                      bilateral - one that required me to go to the Soviet Union at least once a year. So, I
                      carried both those enterprises with me when I went to EPA. Of course, we had an
                      international office at  EPA in the Office of the Administrator, which I inherited from
                      Ruckelshaus. It was kept very busy during those years with a  good deal of bilateral
                      activity with Japan, Germany, Poland, Mexico, and Canada, among others. We
                      signed with Canada a highly developed Great Lakes water quality agreement which
                      was negotiated when I was at CEQ. International activities were very important to
                      me when I was at EPA.


                      Train's achievements and legacies

                      Q: What your lasting achievements as EPA Administrator?

                      MR. TRAIN: In a general sense, all through the various energy crises of the 1970s
                      we succeeded in holding the environmental line. We never did get pushed back in
                      any significant way. One of our main achievements was putting into place the
                      National Pollution Discharge Elimination Permits (NPDEP) program. Despite Ed
                      Muskie's opposition, we borrowed this program from legislation that long pre-dated
                      any of the current environmental legislation. We latched onto it as a basis for
                      imposing discharge limitations, wrote it into the Water Pollution Control  Act, and put
                      it into effect nationwide. It is really the basis of the Water Pollution Control Program
                      which exists today. It was a huge achievement.
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EPA History - Russell E. Train: Oral History Interview                                  Page 17 of 18
                      I don't say this to be pejorative about other periods in EPA history, but I think we did
                      a pretty good job of building the credibility of the Agency from 1973 to 1977. We
                      didn't have any major setbacks insofar as public confidence in the Agency was
                      concerned. We were able to resolve political problems within the Administration
                      and the White House in a way that did  not diminish respect for the Agency. We also
                      had good Congressional  relations. Again, the most important thing we did was to
                      build the credibility of the Agency with the public.


                      Cabinet status

                      Q: Do you think cabinet status will improve the standing of the Agency?

                      MR. TRAIN: Yes, I think it would  be a good thing.  I have testified to thiseffect
                      before  Congress, so I am clearly  on record. It is not going to be  a solution to the
                      problems that EPA confronts day in and day out. In some ways, it may make some
                      of them more difficult. But, in my mind, it clearly gives the Agency more clout:
                      politically, publicly, with the Congress, and around the world. I think that more and
                      more the environmental issues we have to deal with  involve interfaces with other
                      major public concerns,  such as energy, transportation, agriculture, trade, and so
                      on. The environmental  side of the equation will be better served if the principal
                      institution speaking for  the environmental side is of equal status with these other
                      groups. I think it is very important from that standpoint. I also believe that as a first
                      step, the practical thing is simply  to create the present EPA as a department
                      without adding many other functions from around the government. I believe that in
                      due course, and sooner rather than later, the  Department of the Environment
                      should  include new functions, such as those found in NOAA. I think these steps
                      would go a long way toward helping build the kind of scientific capability and
                      scientific credibility the  Agency needs.


                      Final observations

                      Q: Do you have any final observations to make?

                      MR. TRAIN: I've talked long enough! I  should mention that, in my judgement, the
                      Cancer Advisory Committee that  I set up is really the beginning  of what is now
                      called risk assessment, which has become an awfully important theme of EPA.
                      Then as now,  it wasn't  hard to do laboratory tests and develop data which showed
                      that if you fed  so many mice so much of one ingredient for a given length of time, it
                      would develop a malignant tumor. This meant there was a risk of cancer in those
                      particular materials. But that was  not terribly helpful.  Somehow,  you have to get
                      beyond that and determine the magnitude of risk, learn at what level of exposure
                      risks may occur. These were the tough questions, and I had a feeling the public
                      never really appreciated their complexity. Certainly, Congress seldom did. So, I
                      think the field of risk assessment  has been extremely important, and is one the
                      Agency must continue to  give a lot of attention to.  Bill Reilly has done this through
                      the Science Advisory Board, which  has made very important contributions.  I like to
                      think we started the trend.

                      I would also like to make  a general comment on EPA relationships with the White
                      House  and OMB. I gave an interview not long ago to public radio, and the
                      interviewer said, "Isn't it awful how the White House  and OMB interfere with EPA in
                      carrying out its responsibilities?" I reminded them that this is nothing new. It's been
                      going on for a long time. I do think it's become more  intrusive, more pervasive. It
                      does seem to  me that the White House today pays more detailed attention to what
                      EPA does than was ever true in my day. Having said that, the White House and
                      OMB always had a fairly lively interest in our regulations. While we didn't have a
                      Competitive Council, we did have something called the Quality of Life Review. But
                      it acted more to  delay than to prevent initiatives. In my opinion, in the 1970s, EPA
http://www.epa.gov/history/publications/print/train.htm                                      8/24/2004

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EPA History - Russell E. Train: Oral History Interview                                    Page 18 of 18
                       did not have the difficulties with the White House that it has today. My point is that
                       such interference is not really something new, not something dreamed up by the
                       Bush Administration or Reagan Administration. There was a good deal of it in the
                       Carter Administration, and it certainly went on in the Nixon and Ford
                       Administrations. But, I do think it has become more difficult.

                       Q: Mr. Train, thank you for this enlightening discussion.

                       MR. TRAIN: You  are welcome.
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                                        URL: http://www.epa.gov/history/publications/print/train.htm
http://www.epa.gov/history/publications/print/train.htm                                       8/24/2004

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