Second Circuit Holds Citizen Suit Central Enforcement Device Under the Clean Air Act
One of the most novel enforcement mechanisms devised by the drafters of the Clean Air Act Amendments of 1970 was §304's "citizen suit" provision.1 This section, variants of which were later incorporated in the Federal Water Pollution Control Act Amendments of 19722 and a number of other federal environmental statutes,3 authorizes any person to commence civil enforcement suits in federal district court.