petitioned, the EPA is required to respond to the petition within 180 days. There are certain

exemptions for special cases of known ozone depletors, however the specifications under which

methyl bromide would qualify are unclear.

 On December 3, 1991 the Natural Resource Defense Council (NRDC), the Environmental

Defense Fund (EDF) and the Friends of the Earth (FOE) petitioned the EPA requesting that EPA

add methyl bromide to the list of class I ozone depletor substances, reduce production of methyl

bromide by fifty percent by 1992 and accelerate phaseout of methyl bromide by January 1, 1993.

 "The petition also requested that EPA order this accelerated phaseout of

 methyl bromide based on the (EPA) Administrator's emergency powers

 under section 303 of the (Clean Air) Act to protect public health or

 welfare or the environment" (EPA, 1993 p. 15030).

 The Methyl Bromide Working Group is an industry group comprised of the three major

methyl bromide manufacturers. The Methyl Bromide Working Group responded to this petition

by submitting two letters to the EPA Administrator regarding the addition of methyl bromide

to the list of ozone-depleting substances. The first letter emphasized the lack of evidence

implicating anthropogenic sources of methyl bromide in the destruction of the ozone and

maintained that this lack of evidence does not warrant emergency action by the Agency under

section 303. The second letter called for the denial of the petition again citing the scientific

uncertainty of the impact of anthropogenic sources of methyl bromide on the atmosphere (EPA,

1993).

 At the fourth meeting of the Montreal Protocol, an international agreement between

 member nations to oversee the manufacturing and trade of ozone depleting substances, members