January 01, 2016

Interview: John C. Cruden

Milo Mason

John C. Cruden was confirmed by the U.S. Senate on December 16, 2014, as the Assistant Attorney General (AAG) for the Environment and Natural Resources Division (ENRD). Before becoming AAG, Mr. Cruden served as president of the Environmental Law Institute, a nationally recognized bipartisan organization, and prior to that was the career deputy assistant attorney general for ENRD from 1995 to 2011 and chief of the Environmental Enforcement Section from 1991 to 1995. Mr. Cruden has a long history of public service at the Department of Justice and in the military, including serving as the chief legislative counsel of the Army and as a military prosecutor, and has received the Presidential Rank Award from three different presidents, among numerous other military and civilian awards.

NR&E: Assistant Attorney General for Environment and Natural Resources, John C. Cruden, on behalf of the editorial board of NR&E, I thank you for this interview. What does your part of the Department of Justice (DOJ) do, for those who aren’t familiar with it?

CRUDEN: The Environment and Natural Resources Division is an important and highly regarded litigating division within the Department of Justice. As the chief law enforcement agency, the Department of Justice has a much broader purview, which includes the Bureau of Prisons, the Federal Bureau of Investigation, the Drug Enforcement Administration, and several litigating divisions. But the Environment and Natural Resources Division is quite important and plays the primary federal role of directing litigation in the areas of environment, energy, natural resources, and Native American law. It is also one of the older divisions, more than 100 years old.

The division is also the nation’s largest environment and natural resources litigator, with about 650 employees, including 460 attorneys. As our name implies, the division can be divided into two parts: an environmental group, which has three sections (Environmental Crimes, Environmental Defense, and Environmental Enforcement), and then a natural resources part, which has four sections (Natural Resources, Indian Resources, Land Acquisition, and Wildlife and Marine Resources). Rounding out the ten sections of the division is our Executive office, the management element; an Appellate Section; and a Law and Policy Section. Right now the division is responsible for more than 6,000 cases or matters, half of which are offensive and about half defensive. The division represents every agency in the federal government, but the top five agencies we work with are the Environmental Protection Agency and the Departments of the Interior, Defense, Commerce, and Agriculture.

NR&E: Do you have an enforcement philosophy and, if so, how does it differ from others at the DOJ?

CRUDEN: We are fundamentally a law enforcement agency, and I want each of our cases to be firmly grounded in both statutory and regulatory authority. I am emphasizing environmental enforcement as a key priority for the division and am pushing the division to make each one of our cases timely, comprehensive, and fair. It remains a great thrill for me to stand up in court and advise a judge that I am speaking on behalf of the United States, and with that privilege comes unique responsibilities. Each of our lawyers is instructed on the importance of fairness, ethics, integrity, and the rule of law in all that we say and do on behalf of the United States. Our approach to enforcement is similar to that of DOJ as a whole. We place great emphasis in our civil actions in obtaining injunctive relief, mitigation, and supplemental environmental projects as well as penalties.

NR&E: Have you set any goals for the division?

CRUDEN: Yes. I did what I said I would do in my confirmation hearing before the Senate; that is, I reached out to the members of the division, and we jointly developed five overarching goals for what we will strive to accomplish during my tenure as Assistant Attorney General. The first goal will not surprise you: vigorously pursuing environmental enforcement of all types, which includes appropriate considerations of environmental justice in all that we do. One major aspect of enforcement that I am focused on is acting to take any profit out of illegal activity. As we evaluate misconduct, we are also evaluating the profit that a company gained by their illegal activity, and by using the tools that are available to us, we are attempting to take that profit away because I firmly believe that will help level the competitive playing field and protect those corporations that are actually spending a lot of money to comply with the law.

Our second goal is to continue to provide exceptional representation of the United States in federal trial and appellate courts and effectively advance the missions of our client agencies, including by defending EPA’s important rulemaking authority, which has been challenged in both the Clean Air and Clean Water contexts. The third goal is to protect the public and defend the interests of the United States. The fourth is to promote and defend tribal sovereignty, treaty rights, tribal natural resources, and the environment in Indian country. And the fifth goal is to provide effective stewardship of the nation’s public lands, natural resources, and animals, including fighting for the survival of the world’s most protected and iconic species.

NR&E: Do you think you can ever get a level playfield? I’ve asked this question to your predecessors at times, and I know there’s a constant effort, but . . .

CRUDEN: That’s a good question, but it’s another version of the question I am often asked: what difference do you make in your cases? The number of cases that we file goes up and down depending on the year and the conduct, but we just finished six months with extraordinary results by any way that success is measured. We brought more cases, included comprehensive injunctive relief in our civil cases, and important conditions on probation in criminal cases, we achieved significant penalties, and worked closely with a number of states on key cases. I can say without hesitation that our cases during this time have given many communities, including Native American and economically disadvantaged locations, cleaner air, drinkable water, and safe land that did not previously exist. In addition, our Environmental Crimes Section has dramatically increased our wildlife criminal enforcement because that’s an area of criminality that has significantly increased in the last few years.

NR&E: Is your shop mostly reactive? Do you depend on the agencies, say the U.S. Fish and Wildlife Service, to bring you cases or do you go get them?

CRUDEN: Our cases come to us in a variety of ways, and it makes some difference whether or not you’re on the civil side or on the criminal side. As we do not have investigators of our own, we rely on some really superb agency investigators and attorneys at EPA, DOI, DOA, Customs Service, Coast Guard, DOD, and others. In our vessel pollution cases, for instance, we rely heavily upon the Coast Guard to find and investigate the illegal conduct, which is frequently dumping pollution into U.S. waters before the ship enters one of our ports. Federal agencies, as well as state and local municipalities, also bring illegal conduct to our attention, as do citizens in the form of citizen suits.

NR&E: How do you decide between the cases or which ones you take and which ones you tell the agency “settle”? I mean, is there any bright lines or is there just the deterrent bang for the buck if you take the case? Or is there some other calculus?

CRUDEN: We triage each case that comes to us, determining whether it will be a civil or criminal case, whether there is a statute of limitations or bankruptcy bar date approaching, and whether some form of immediate action is necessary to protect human health or the environment, preserve evidence, or immediately stop ongoing illegal conduct. When we take a case, we are prepared to litigate it to its conclusion; in civil cases, we offer whenever possible the opposing party an opportunity to settle before bringing the case. When we consider settlement our criteria is straightforward: would the settlement achieve a better result for the U.S. than litigating the case to conclusion? Our approach to each case is quite rigorous, with a thorough review of all available evidence, all applicable law, and litigation risk. We’re fortunate in the Environment Division because we’re also working with 94 U.S. Attorney’s Offices across the country, particularly in criminal cases where we are often sharing the workload.

NR&E: Do you have enough resources?

CRUDEN: I left the division in 2011 to become the president of the Environmental Law Institute and returned in 2015, and we have fewer resources now than when I left. But we’ve been getting more. We’ve been hiring. And this month we will add fifteen of what we call “Honors Attorneys” to our division, who have survived the rigors of being interviewed by us on multiple occasions. And I think it’s good for the morale of the department and a good sign that we are, in fact, hiring new people to come in and join the division. These are really wonderful and talented people.

NR&E: They bring fresh energy and fresh views, and it’s a great training for all of them.

CRUDEN: We’re actually quite unique in the department because when we bring in new lawyers—some of them quite experienced, some of them out of law school—we run a weeklong course for them, universally referred to as boot camp. This weeklong course provides fundamental trial practice advice from highly experienced litigators, and every attorney gets an opportunity to show his or her oral abilities by arguing a practice summary judgment motion before our most senior attorneys. This instruction is really a way to introduce each new attorney to the division and then they also get to see really experienced attorneys teaching deposition practice, teaching expert witness use, or promoting ethics and integrity. And, we are famous for our rigorous moot courts we conduct internally for all major arguments.

NR&E: Any advice for aspiring young environmental and natural resources attorneys who might want to apply to that program?

CRUDEN: I enjoy talking to law students and try to do so whenever I am traveling. Very often I am asked about what best prepares someone to be an environment, energy, or natural resources attorney. My answer usually surprises them as I strongly believe that great practitioners in our area, including those in this division, are those who are conversant in broad areas of the law as our practice goes well beyond environmental and natural resource statutes. Our attorneys need to be experts in the federal and appellate rules of procedure, administrative law, constitutional law, forest management requirements, alternative energy issues, and the burgeoning law of climate change. In addition, they need to have a working knowledge of applicable tax law, bankruptcy law, and relevant state law issues. In short, they need to be well-rounded in addition to having specialized expertise as an environmental law lawyer. Finally, I often tell law students or new attorneys that our practice area is still small enough and new enough that many of us know each other. Accordingly, reputations for honesty, integrity, professionalism, and advocacy matter a great deal and should be protected and nourished along with all other skill sets.

NR&E: Just learn to be good analysts and sharpen one’s legal skills. What causes compliance?

CRUDEN: I actually think that most companies are trying to comply with the law. Most companies, in fact, have a number of compelling reasons to be lawful, including enhancing their own brand, promoting their commitment to law, avoiding employee or shareholder discontent, or simply avoiding the deleterious impact of being on the receiving end of our federal enforcement. And, great environment and natural resource lawyers, like members of this section, are providing timely and important advice to individuals and boardrooms, about the importance of compliance in a competitive marketplace. Now, with advanced publications on environmental management systems, well-trained vice presidents of environment, health, and safety, and knowledgeable employees, compliance is a sought-after goal by virtually everyone. Because of those compliance efforts, our enforcement work is all the more important. Companies that are complying with the law are spending money and utilizing valuable resources to do so, both by acquiring advance pollution control equipment, training key people, and conducting internal audits. Any company that is not committed to compliance and engages in illegal conduct could gain a competitive advantage by not having spent the money that a competitor did to comply with the law. Therefore, our effort to both enforce the law, and take any profit out of illegal conduct, is critical to protecting the compliance efforts of our best companies in each major field.

NR&E: Do you have settlement guidelines, and how often are they changed and how closely do you follow them?

CRUDEN: Settlements are an important part of what we do and they are often the best way to resolve a case. By Executive Order, before bringing a civil case, we normally give the defendant an opportunity to settle. We do that by sending a letter to the corporation or individual indicating that we plan on suing in the very near future, providing a summary of the alleged offenses, and giving some idea of what a settlement would require. As we litigate a lot, we obviously do not settle every case at the beginning. And, I am always surprised when a defendant does not respond at all to the letter, as the attorney sending the letter usually has an approved complaint ready to file. We are, however, able to settle a number of cases at this early stage, which is often in the best interests of both parties. The transaction costs are not nearly as high at that particular stage and a company can get through the enforcement process in a much more rapid fashion. But if it doesn’t work, then we do proceed to litigation. Sometimes we’ll establish liability first and then go back and attempt to settle the remainder of the case.

In some instances, like a CERCLA Superfund RD/RA agreement, those are model consent decrees, with very standard terminology. But in most instances, we’re really settling cases based on the unique circumstances of that particular case. On the civil enforcement side, we seek public comment on most of our consent decrees, and those consent decrees are placed on our website for public awareness. Therefore, more experienced practitioners know that they can go on our webpage at any given stage and download a number of examples of consent decrees. And so, although we do not have an absolute standard cookie-cutter approach for our consent decrees, we do have a great deal of experience in virtually every area and past agreements to draw from.

NR&E: You’re putting a renewed emphasis on skimming off all the profit from noncompliance? Is that new to you or is that just a reemphasis?

CRUDEN: I think it’s an emphasis I am personally passionate about. It’s what the Environmental Protection Agency would call the economic benefit of the illegal competitive advantage, and the concept has been around for quite some time. But it’s true now that, particularly with the Enforcement Section, when they are giving a recommendation to me as to whether or not we should settle a case, they know that I will look at whether any penalty number includes, at a minimum, the amount of illegal profit gained, so that I can examine whether or not the settlement will achieve our law enforcement objectives.

NR&E: What are the top two or three issues you’re dealing with now?

CRUDEN: Well, you’re asking me today, which is . . .

NR&E: (laughter) This afternoon.

CRUDEN: Right as we’re speaking, the President of the United States is in the Rose Garden announcing the two new EPA Final Rules giving greenhouse gas reduction requirements for future and existing power plants, which will, without question, give us more work.

NR&E: If they only come up to 31 percent reduction, say, instead of 32 percent, you’ll see them in court, right?

CRUDEN: Well, long before we enforce these rules, we will be defending them in court. They are, however, critical rules for the future of this nation, and we welcome the opportunity to defend them.

The major enforcement action we are involved in right now is implementing the Agreement in Principle that we have with BP regarding the Deepwater Horizon disaster. On July 3 we announced the Agreement in Principle with BP. The department announced it as the largest settlement with a single defendant in the history of the Department of Justice, and at that stage it was announced at $18.7 billion. But that was an Agreement in Principle, so now we are working on our consent decree, so no one’s surprised that that one’s high on our list. We are also defending the Department of the Interior’s hydraulic fracturing rule as well as EPA’s water jurisdiction rule.

NR&E: How many states sued you on that one?

CRUDEN: We’re in the double digits.

NR&E: They’re just trying to clarify Rapanos right?

CRUDEN: Yes. And we’re already now at ten district courts and eight courts of appeals. So we’ll have to work diligently at figuring out jurisdiction in those particular cases before we get to the merits of that important rule. And we also have just a number of quite important natural resources cases, defending actions by the Department of Interior. Those include a number of alternative energy cases, siting of wind and solar, oil and gas exploration, and land-related issues. The Department of the Interior is responsible for 20 percent of the land mass of the United States, and that generates a number of important legal issues.

NR&E: Do you have any environmental justice cases for Native Americans these days? Are those mainly in the siting cases?

CRUDEN: When I told you that I had set goals for the division, I mentioned that the first goal was the vigorous enforcement of the laws, including environmental justice. And I have a very broad notion of what environmental justice means. I view it as giving voice to individuals or groups of individuals who would not otherwise have a voice. And so one example that we have been emphasizing, which is an important goal of mine, is to look at pollution on Indian Land. We’ve now been able to do so in several different cases that have had a dramatic impact on the environment and health of Native Americans. The most recent one involves litigation concerning a power plant settlement on Navajo land. We were ultimately able to obtain a significant settlement that will reduce sulfur dioxide and nitrogen oxide, which has an almost immediate health impact on the Native Americans in that area. And part of the mitigation measures will include giving tribes there an opportunity to take steps that will improve their health, which will be paid for by the company. So we’re looking at environmental justice broadly, looking at those communities that suffer the adverse effect of pollution over the years, but we’re also looking again, very specifically, at pollution on Indian Land.

NR&E: What percentage of time do you spend lawyering versus administrative and personnel issues in your position?

CRUDEN: I would say I would spend 100 percent of my time lawyering, but very often people ask how much time are you personally doing things versus supervising the wonderful people in the division? And it varies. I led the negotiations in Deepwater Horizon, so I spent a considerable amount of time either in Washington D.C. or in New Orleans, leading that effort. I testified before Congress twice, and I personally led two different international meetings. And, I am meeting with a number of judges. But, by and large, the responsibility of the Assistant Attorney General is to approve the complaints and approve the appellate briefs and approve the litigating position of the United States. So I’m meeting with our teams every single day, and we’re trying to determine whether the facts we have assembled present an appropriate case for us to bring. And if we are bringing it, are we, in fact, using the right law? Are we telling courts what they need to hear? Are we taking into consideration the positions of the relevant federal agencies? Are we being fair? As someone in the department I admire greatly, Dave Margolis, once said: “It is well to remember that we are the Department of Justice, not the Department of Prosecution.” I try to remember that in each case we bring, as we are a law enforcement entity.

NR&E: What’s your most memorable moment in your federal career?

CRUDEN: Two thoughts: I was confirmed last December by the Senate and came to work the first week of January. The second day that I was here I led the moot court for the Deepwater Horizon trial team because we needed to go to court and tell the Judge what we thought the penalty should be. I then immediately went to New Orleans to be with the trial team. Our case went in well. Then, when BP contacted us to reopen negotiations, I felt confident of our legal position and our likely success on a penalty decision. That enabled me, and the exceptional team that we assembled, to obtain in settlement what has been described as the largest settlement with a single defendant in the history of the Department.

Here is another activity that just gave me a lot of pleasure. Over the weekend I was in Chicago for the American Bar Association’s Annual Meeting. I was speaking and then stayed because they were giving one of our attorneys the Government Lawyer of the Year Award. So I was able to stand up and present Jim Lofton to the group. Jim is our senior counsel for power plant litigation. Our power plant litigation started when Janet Reno was the attorney general, and it has lasted through both Democratic and Republican administrations. We have now had over thirty power plant settlements across the United States and the amount of pollution reduction that has been achieved because of those cases is getting close to three million tons a year. And so the combination of being able to honor Jim, who’s led a lot of that effort, but also to be able to look back and see the impact of enforcement, very often on the health of people in that area, is, I think, one of those things that just thrills me and also one of the things that I really do think makes what we’re doing so valuable to the country.

NR&E: What do you enjoy most about lawyering or have enjoyed most about lawyering?

CRUDEN: Of all your questions, that is the one easiest for me to answer. The opportunity that I have to work with really a wonderful, wonderful group of the division’s attorneys, paralegals, and staff is a real honor. The opportunity to work with really committed career people, who every single day are doing their best to promote the environment, to advance environmental goals, and to increase and fulfill the responsibilities for the rule of law. Without question, that’s the part of the job that I like the best.

NR&E: What do you enjoy least about lawyering?

CRUDEN: That’s more difficult and on some days is a considerable list, probably . . . (laughter) of things. I love being a lawyer, but have many nonlawyer responsibilities that can be time-consuming. Soon we will go through another drill to determine whether the federal government must shut down because Congress has not appropriated money for us to do the nation’s work. Even the preparation for that possibility is lost time for me and the division. And, it angers me that we still have individuals and corporations who are blatantly violating the law, often putting other individuals’ health or environment at risk. When that happens, we will bring the full resources of the division to bear to stop and correct such harmful illegal conduct.

NR&E: What’s the most important thing you’ve learned?

CRUDEN: Well, my wife would say patience, which I am not good at a lot of times. When I see injustice or clearly illegal behavior, I am anxious for us to do something immediately. Yet, I have learned and relearned three valuable lessons. First, to value the views of the American public in all that we do. The input we receive in our public comment process, through meetings with environmental justice and other groups, and with local communities is invaluable. Second, I am completely buoyed by the extraordinary expertise available to us in federal agencies, who work diligently to improve the nation. In the Deepwater Horizon negotiations, for instance, I was able to draw senior officials from NOAA, the Department of the Interior, Coast Guard, EPA, and Department of Agriculture into the equivalent of an environmental “dream team,” who were truly exceptional and are coming up with an exceptional settlement. Finally, the men and women of the Environment Division are the people I value the most. Their hard work, commitment to the rule of law, and strong advocacy to improve the nation in every one of our cases is quite exceptional. I have learned again to rely heavily on their advice and recommendations in all that I do on their behalf.

NR&E: Cecil the lion just got shot and killed. What are you doing in illegal wildlife trafficking? Does the division ever get involved in extradition?

CRUDEN: Wildlife issues, particularly wildlife trafficking is, again, a very significant goal of mine. It is right now in the world a billion-dollar, multibillion-dollar criminal endeavor. When I testified before the House Foreign Affairs Committee several months ago, I testified that the trajectory that we are on could actually end elephants and rhinoceroses in our lifetime, and that is due in no small way to greed and criminal activity. There are individuals who are killing these wonderful beasts for their tusks. We do have any number of programs going on including Operation Crash, which is our effort to fight the trade in rhinoceroses’ horn, and we’ve already had a whole series of criminal prosecutions because that activity very often violates the Lacey Act which is a criminal statute. So clearly there are people going to jail and paying significant criminal fines for very intentionally violating the law. You mentioned extradition. We do not have worldwide jurisdiction over all illegal hunting activities, although we do have the Lacey Act, which gives us a powerful criminal tool in some cases to seek extradition of defendants beyond our borders. And that kind of cooperation demonstrates a genuine commitment on a global scale to end this devastating attack on endangered species.

(Editor’s Note: After this interview took place, Patrick Sheridan, an Irish national arrested in January 2015 in the United Kingdom pursuant to a request by the United States, was extradited to the United States on September 18, 2015, to face charges in federal court in Waco, Texas, for his role in trafficking black rhinoceros horns.)

The strong public outcry surrounding Cecil the lion is also indicative, I think, of a broader concern that the American people have for the humane treatment of animals. And that is an area that the Environment Division will be working more in, partnering with colleagues in the Department of Agriculture to ensure that whether we’re dealing with underground dog-fighting rings or mistreatment at zoos, our federal animal welfare laws are complied with.

NR&E: You recently gave a speech on surging in enforcement efforts. What’s that all about?

CRUDEN: Yes. I have now given several speeches emphasizing enforcement, and those speeches are now on our website and have been reported in several different newspapers. I’m really talking about what I thought of as an enforcement surge, looking narrowly at what has happened the last six months in the division, and I was able to, not just with Deepwater Horizon, which is obviously the most significant environmental case of all time, but to detail civil and criminal cases that have come just within the last six months. And the numbers are actually quite extraordinary. Both in terms of the quantity of how many cases we’ve been able to bring during that time period, but also qualitatively, meaning just the significance of the health effects and of pollution reduction. I took the opportunity in that speech to also talk about something else that’s quite important to me, and that is joint enforcement with states.

In those speeches I also announced that I have created a new position inside the division, a Counselor on State and Local Matters. I have chosen a very experienced career litigator for the position, and she is now reaching out to states and promoting joint enforcement. Over a dozen of the cases that I have announced this year as significant enforcement cases were ones that we did jointly with one or more states. And, we shared penalties with the states in each of those cases. On Earth Day this year, for instance, I announced two really significant settlements, Noble Energy in Colorado and Exxon Mobile’s big spill in Arkansas, and both of those cases involved sharing penalties with states; both of those were joint enforcement.

I created this position to make it very clear how important we think state and local governments are, not just in environmental enforcement but to our law in general, to give real meaning to the principle of federalism that underlies our framework of environmental law.

NR&E: I talked with a professor who said that often the EPA just deferred to the states and the states too often in her cases turned a blind eye. Maybe your efforts in getting them to jointly enforce might help them see more?

CRUDEN: Although I am quite proud of what we have recently accomplished in our key enforcement cases, states without question do more enforcement actions collectively than the federal government does. By promoting joint enforcement, which I am doing, I believe we combine the best of our abilities into a single action. The state or local government is closest to the polluting activity and is often best at gathering the facts and evidence about existing and future harm. We bring strong federal statutes, experienced litigators, and a willingness to work cooperatively to bring a positive result for both the state and federal governments. And, I believe we increase the capacity of the state enforcement effort in the process.

NR&E: EPA’s efforts in the next generation enforcement . . . What are your thoughts on that?

CRUDEN: I am a great supporter of EPA’s Next Gen initiative. We are fully embracing all of its components and are working with EPA to enhance its reach. And, we are also seeing concrete results right now. I mentioned to you one of the cases that I announced on Earth Day, dealing with the Noble Energy company, whose tank farms were leaking volatile organic compounds. To the naked eye, there would be nothing, but now with state-of-the-art technology you can actually use a handheld device that shows the emissions. Now the company is adopting that technology, which will improve compliance. There are countless other examples of technology making a difference. I am convinced that in our lifetime we will be using smartphones to monitor emissions, along fence lines or even test water samples in ways that will revolutionize environmental enforcement and compliance. We and EPA are also looking at big data issues so that we can use our computer capability to better evaluate environmental trends.

These efforts are enormously beneficial and I’m really impressed that we have groups of individuals in the federal government looking specifically at ways to improve what we do. Some of that will be now, some of that will be in the future. And, this type of thinking by the federal government can also have a positive effect on the states, which are also trying to use their limited resources in the most productive way possible.

NR&E: So you’re very optimistic that technology can help enforcement and compliance.

CRUDEN: Yes. Next Gen’s technological emphasis is a positive vision for the future, and it is having a great impact right now in our cases. Some of Next Gen is really kind of straightforward but incredibly valuable. As an example, a Next Gen initiative includes having a third party come in, paid for by the company, to audit compliance with a consent decree. I think this can be quite an excellent tool, because once we actually finish a settlement and get the court to approve it, we want to make sure it’s complied with. And having a third party monitor and then publish the information on a website so that the public can see it, and know that, in fact, what’s being promised in the settlement is being delivered to the public.

NR&E: And trying to do more with less is constantly an issue in the federal government. The Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE) is trying to wrestle that bear to the ground, too. While they’ve gotten more money for offshore inspectors, the tasks are almost unlimited.

CRUDEN: We brought our first cases for BSEE and they were successful and so we see that as an area of future growth. BSEE has hired a former senior litigator from this division, and she is already producing future enforcement cases of merit.

NR&E: Yes. Thank you, John. Appreciate this interview.

CRUDEN: You’re welcome. I’m glad the magazine is doing these interviews. I obviously have a special connection to not only NR&E but also the Section at large. It was my honor to serve as the [2009-2010] chair of the Section of Environment, Energy, and Resources. Some of my best friends are working to keep the Section’s well-deserved reputation as the premier environmental forum, and I honor each member who is working to protect and enhance the environment.