Environmental Protection Agency acted arbitrarily and capriciously in classifying as not cognizable under Section 21 of Toxic Substances Control Act environmental groups' petition to regulate spent lead bullets and shot, because: (1) Section 21 unambiguously authorizes any person to bring petition for rulemaking to regulate toxic substances and does not provide EPA authority to dismiss petitions as not cognizable under TSCA, and (2) even though EPA argued two of environmental groups filed similar petition previously and it must have authority to define repetitive petitions as not cognizable to give effect to 60-day period in Section 21 to commence civil action to initiate rulemaking after denial of petition, 99 environmental groups were not party to previous petition and EPA and courts can address repetitive petitions without undermining citizen petition provision of TSCA.
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