Editors' Summary: Fee shifting provisions continue to be a vital concern both for those who seek the awards and those who may have to pay them. The law of fee shifting has swung through a series of changes in the past ten years, with Congress and a few courts promoting awards while the Supreme Court has generally discouraged them. Two developments in recent months well illustrate this pattern: Congress has revived and amended the Equal Access to Justice Act, expanding opportunites to claim fees from the federal government, and the D.C. Circuit in Sierra Club v. EPA has applied recent Supreme Court rulings to carefully scrutinize fee requests under the "appropriate" standard of the Clean Air Act. This Comment reviews those developments and also previews the issues in Pennsylvania v. Delaware Valley Citizens' Council for Clean Air, an attorneys fees case the Supreme Court recently agreed to hear.