With its recent decision in Friends of the Earth v. Consolidated Rail Corporation, the Second Circuit reasserted its role as one of the leading players in the development of environmental law in the United States. The case involved efforts by private environmental organizations to enforce water pollution standards established under the Clean Water Act. These actions had been brought pursuant to the citizen suit provision, which grants private rights of action to those seeking enforcement of the Act. The court first held that the plaintiff organizations had the necessary standing under the standards established by the Supreme Court in Sierra Club v. Morton. It then went on to hold that based upon the ‘plain meaning’ of the Clean Water Act, state agency enforcement actions did not preclude the plaintiffs from seeking judicial enforcement of the pollution standards. The Friends of the Earth standing decision is important because it strengthens the hand of citizens' groups seeking enforcement of the Clean Water Act through the Act's citizen suit provision. The decision has broader implications in the field of environmental law generally, since several other environmental statutes contain citizen suit provisions under which the same standing issue could arise. The second aspect of the court's decision is of even greater significance; it reaffirmed the vitality of the ‘plain meaning rule’ of statutory construction in the face of a third circuit decision reaching a contrary interpretation of the same statutory provision. In so doing, the court not only simplified citizen suit litigation under the Clean Water Act but also reaffirmed an approach to statutory construction that would streamline litigation in general and assure that judicial decisions take their proper place in a democratic system. This article first traces developments in environmental law under the National Environmental Policy Act of 1969 (NEPA), the Clean Air Act, and the Clean Water Act. Then it examines the Second Circuit's role in the field of environmental law. Next, it discusses the court's decision in Friends of the Earth and focuses on the issue of plaintiffs' standing and the proper method for determining standing under the Clean Water Act. Finally, it discusses the propriety of the Second Circuit's reliance on the ‘plain meaning’ method of statutory construction.