The WTO and the Kyoto Protocol

I wonder whether members of the WTO could make a case at the WTO Court in reference to GATT Article XX which exempts from certain obligations if "necessary to protect human, animal, or plant life and health" in order to pressure USA, China, and India to sign the Kyoto protocol. Especially since today scientific evidence is mounting that greenhouse emissions are responsible for climate change and those three countries together are the biggest producers of greenhouse gases.