The National Cattlemen’s Beef Association (NCBA) and an informal coalition of companies and trade associations representing U.S. energy and mining sectors submitted comments to the Environmental Protection Agency (EPA) today regarding a recent EPA proposal to find that human-caused greenhouse gas (GHG) emissions are an endangerment to public health and welfare. The proposed finding, released by EPA in April, is the first step in a process that could require GHG regulation under the Clean Air Act (CAA) — a move that would be devastating to the agriculture sector, and the U.S. economy as a whole.
“With so much scientific uncertainty surrounding the question of whether human activity is responsible for climate change, it is inappropriate for the EPA to only consider one side of the debate — especially considering the devastating consequences that their actions could have on an already struggling
The EPA has said that manure management facilities associated with livestock production account for less than 1 percent of total U.S. GHG emissions. Regulation of these emissions would be inconsequential to the climate change equation. Rather than being unnecessarily regulated, agriculture should be considered an important solution to climate change.
The comments submitted to the EPA are based upon a number of extensive climate studies conducted by leading environmental scientists from across the world. The following is an excerpt:
“…We submit that there is neither a sound nor adequate basis to make a Finding of Endangerment to public health or welfare from anthropogenic greenhouse gases under Section 202(a) of the Clean Air Act. EPA’s Proposed Finding fails to acknowledge the profound uncertainty that pervades the current state of scientific knowledge related to human-caused climate change. Instead, the Administrator has touted a supposed ‘scientific consensus’ while unduly relying on speculative and uncertain data and models, resulting in a Proposed Finding that is nothing more than a tissue of assumptions, presumptions, and unsubstantiated science. Nor has EPA weighed or considered the powerful and substantive scientific evidence from many of the world’s scientists calling into question whether climate change is within the range of natural variation or otherwise challenging many of the assumptions on which EPA’s proposed finding is based. The Administrator has failed to conduct a balanced, scientifically-based evaluation of the net effects on public health and welfare – positive as well as negative – from warming temperatures. Moreover, regulation of greenhouse gases under the CAA will have severe economic consequences through a regulatory cascade, with no or de minimus net environmental benefit.”
The groups are urging EPA to postpone regulation until climate science can address the profound uncertainty that currently exists in climate data and modeling.
“Before mandating drastic regulation on
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